In re Pashchimanchal Vidyut Vitran Nigam Limited (AAR Uttar Pradesh)
The Uttar Pradesh Authority for Advance Ruling (AAR) has addressed key questions raised by M/s Pashchimanchal Vidyut Vitran Nigam Limited (PVVNL) regarding the applicability of Goods and Services Tax (GST) on deposit works undertaken by the company. PVVNL, a subsidiary of Uttar Pradesh Power Corporation Ltd., sought clarity on whether its involvement in deposit works for electricity infrastructure development qualifies as a taxable supply under the Central Goods and Services Tax (CGST) Act, 2017.
The Application for Advance Ruling
PVVNL, registered under GST with GSTIN 09AAECP5610N1Z4, filed an application under Section 97 of the CGST Act, 2017. The company sought an advance ruling on three specific issues:
1. Whether undertaking deposit works qualifies as a supply under Section 7 of the CGST Act.
2. The value of such supply under two distinct methods of deposit work execution.
3. Eligibility to claim Input Tax Credit (ITC) on materials, labor, installation, and overhead expenses under the second method of deposit works.
PVVNL filed the application on September 22, 2023, which was received by the AAR on May 13, 2024. The ruling was sought to determine the GST implications of the company’s role in executing or supervising deposit works requested by consumers or intending agencies.
