In re Suzlon Energy Limited (GST AAR Gujarat)
The specially designed Transformers for Wind Operated Electricity Generators which are meant to perform dual function of Step Down and Step Up manufactured by Suzlon and supplied to the customers of Suzlon as a part of Wind Operated Electricity Generator be treated as part of Wind Operated Electricity Generator and falls under Sr. No. 234 in Schedule-I to Notification No. 01/2017-Central Tax (Rate) dated 28th June, 2017 read with Notification No. 1/2017- State Tax(Rate) dated 30th June, 2017 and liable to Central GST at the rate of 2.5% along with Gujarat State GST at the rate of 2.5% up to 30th September, 2021 and 6% each towards CGST and SGST with effect from 1st October, 2021 by virtue of omission of the said entry and addition of Entry No. 201A to Notification No. 01/2017-Central Tax (Rate) dated 28th June, 2017 vide Notification No. 08/2021-Central Tax (Rate) dated 30th September, 2021 read with Notification No. 08/2021-State Tax(Rate) dated 30th September, 2021?
FULL TEXT OF THE ORDER OF AUTHORITY FOR ADVANCE RULING, GUJARAT
Brief Facts
M/s. Suzlon Energy Ltd. (hereinafter referred to as Suzlon for the sake of brevity) submits as follows:
2. It is primarily engaged in supply of goods required for setting up of power projects, enabling generation of power through renewable sources of energy on its own and through its subsidiaries companies.
3. Suzlon manufactures Wind Operated Electricity Generators ( hereinafter referred to as WOEG for sake of brevity) falling under Chapter 85023100 and parts thereof mainly consisting of the manufacture of Nacelle, Blades and Towers falling under Chapter Heading 8503 and allied products being considered as parts falling under Chapter 85030090 suitable for use solely or principally with the machines of Heading 8501 or 8502 and the Transformers specifically meant to be used with WOEGs and falling under Chapter Heading 8504.
4. Suzlon submits that it receives Orders from for supply of WOEG consisting of Nacelle, Hub, Controller, Transformer, Set of 3 Rotor Blades and hybrid Lattice Tower – a component of Renewable Energy Device / Wind Operated Electricity Generator in respect of a Wind Farm Project.
5. Suzlon receives a consolidated contract for supply of Wind Turbine Generator consisting of WOEG (nacelle including hub, controller – microprocessor, accessories, set of 3 rotor blades, hybrid tower) and supply of transformer. A copy of Order: Supply/001/SMEIPL dated 30-8-21 entered with Shree Malaiamman Energy India Private Limited was submitted
6. Suzlon submits that the transformer supplied by it is specially designed for WOEG application and is installed on the ground adjoining to each Wind Operated Electricity Generator. Its transformer performs dual function of a Step-Down Transformer and a Step-Up Transformer unlike a normal Transformer. In as much as it performs dual function, it is different from other general use transformers like used by the State Electricity Board, which have a single function of either stepping down or stepping up the voltage, and does not perform both the functions simultaneously.
6.1 Step-Down function: To activate the generator inside WOEG. The transformer draws electricity from the electricity grid of Electricity Board having a voltage of 33kv, and steps it down to 0.690 kv for supply to the WOEG. The voltage of 0.690 kv electricity provided by transformer activates the generator inside WOEG to enable rotation of blades/fan. Further, electricity is continuously required for the monitoring panel etc. installed in WOEG.
6.2 Step-Up function: Once the WOEG starts functioning and reaches the required speed, wind energy gets generated and converted into electricity with the help of generator, which has a voltage of 0.690kv. The electricity so generated is transferred to the transformer, which converts the electricity to higher voltage of 33kv.
6.3 The electricity with higher voltage of 33kv from multiple transformers is then transmitted to a common sub-station which further steps-up to 66/110/132/220/230 kv (as may be required) for transmitting to the grid.
6.4 An image of the Transformer is as below:
7. Suzlon submits that in a Wind Turbine application, the above depicted Transformer specifically meant for use in WOEG is placed either in the nacelle, or in the tower or outside the tower. Due to variable nature of power generation, the transformer is specially designed to withstand intermittent and variable generation loading pattern.
Further, the power electronics converter system in wind turbine is interfaced through this transformer and hence require special design consideration like heating due to harmonics and cyclic temperature variation. Further these transformers are used to suitably step down the grid voltage and connect to the electrical generator. The wind turbine control system needs this voltage to synchronize the generator with grid and feed power into grid. These transformers impedance is used in harmonic filter at turbine level to limit the injection/absorption of harmonics into the grid / Wind Turbine Generator. In addition, reactive power compensation is an important part of grid code requirement and hence these transformers also acts as one of the source for consuming reactive power.
6.1 Suzlon in its submission incorporated the following picutres:
Wind Operated Electricity Generator – Pic:1
Transformer – Pic:2
Transformer – Pic:3
Transformer – Pic:4
7.2 Suzlon submitted key parameters of Transformers in Power, Solar and Wind Applications as follows:
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