In re Shilchar Technologies Limited (GST AAAR Gujarat)
Whether supply of Aluminium Foil Type Winding Inverter Duty Transformer classifiable under Chapter Heading 8504 and parts of Transformer supplied/to be supplied for initial setting up of solar project falls under Sr. no. 234 in Schedule-I to Notification No. 01/2017-Central Tax (Rate) dated 28th June, 2017 and liable to Central GST 2.5% along with State GST at the rate of 2.5%.
AAAR held that
(i) The appellant is liable for payment of GST on the total value of both the Purchase Order i.e. supply of goods and supply of services in terms of Explanation inserted vide Entry No.234 to Notification No.01/2017-Central Tax (Rate) dated 28.06.2017 vide Notification No. 24/2018-Central Tax (Rate) dated 31.12.2018 and liable to be taxed, upto 30.09.2021, as under:
| S. No. | Particulars | % of value | Rate of tax | Effective Rate of Tax |
| 1. | Goods | 70 | 5% | 3.5% |
| 2. | Services | 30 | 18% | 5.4% |
| Total: | 8.9% | |||
Thereafter the same will be covered under entry Sr.No. 201A appearing under Schedule-II to the Notification No.01/2017-Central Tax (Rate) dated 28.06.2017 amended vide Notification No. 8/2021-CT (Rate) dated 30.09.2021 and liable to be taxed w.e.f. 01.10.2021 as under. Explanation stated that out of the gross value of the supply, 70% shall be deemed to be on account of goods and 30% deemed to be on account of service. Accordingly, the effective rate comes to 13.8% as under:
