GST payable on supply & installation of car parking system as works contract

In all the decisions of the AAR pertaining to Works Contract, one point which is very much relevant is not analysed i.e., the definition of goods under the CGST Act visa-vis the definition as provided in the central excise Act. The definitions are entirely different. Goods under cgst act is defined to mean every kind of movable property other than money and securities, but includes actionable claims, growing crops, gross and things attached to or forming part of the land which are agreed to be severed before supply or under contract of supply. Under central excise act excisable goods are defined as the goods specified in the central excise tariff act. From the definition of goods provided in the CGST Act it is clear that things attached to the ground which are agreed to be severed before supply or under contract of supply are also goods. If the car parking systems are capable of being dismantled and erected some where else then they fit into the definition of goods. Similar is the case with solar power generating systems. In view of this the various decisions on the immovable property relied upon by AAR may not be relevant to issue on hand.