States GST & VAT - QUESTION : Applicant is engaged in the development of solar power projects as part of their renewable energy initiatives, and are currently executing a rooftop solar power plant project. The plant is being installed on the factory rooftop of the off-taker, who will be the end consumer of the solar energy generated. A Power Purchase Agreement (PPA) has been executed between the applicant and the off-taker, under which the off-taker will procure solar power generated by the plant for consumption within their factory premises. This arrangement supports the off-taker’s energy cost optimization and sustainability goals, while aligning with their mission to promote clean and efficient energy solutions. Applicant sought advance ruling on the following questions: (1) Whether on the basis of the facts, the applicant which is liable to collect and pay Goods and Service Tax (GST) on intra-State delivery of electrical energy on the basis of the above agreement? If so) then the applicant is needed to apply for an GST Registration in West Bengal and then raise the Bill of Supply of Electrical Energy to its client namely M/s. Shyam Sel & Power Limited formally known as M/s. Shyam Metalics Flat Products Private Limited? (2) Whether on the basis of the facts the applicant can collect and pay Goods and Services Tax (GST) on inter-State delivery of electrical energy on the basis of the above agreement? From its registered office at No.371, SIDCO Industrial Estate, Ambattur, Chennai, Tamil Nadu. Since, we don’t have our branch office situated in Jamuria, West Bengal? (3) Will the outcome of this Advance Ruling will be applicable for all upcoming orders involved in similar transaction of sale of Electrical Energy at PAN India Level? RULING : (1) & (2) As per the facts, the applicant is not required to get GST registration in terms of Section 23 of the Act, as they are engaged in the exclusive supply of exempted goods, namely, ‘Electrical Energy’. (3) As per section 103 of the Act, this Advance Ruling decision is applicable if the law, facts/circumstances contained in this application on the queries raised in any matter referred to in sub-section (2) of section 97 of the Act, is same. Evolve Green Power (P.) Ltd., In re (2026) 130 ITPJ (SG) 327 (AAR) States GST & VAT - QUESTION : Applicant primarily acts as a support center for all of its Group entities located outside India for providing various engineering, IT and IT Enable Services, Back Office and Business process outsourcing services at SEZ Unit. That the Applicant is a company incorporated under the provisions of the Companies Act, 1956 and is primarily a support center for all of its Group entities located outside India for providing engineering, IT and IT enable services, Back Office and Business process outsourcing services at SEZ Unit. That the employees engaged by the applicant are staying in different places outside the MWSEZ area and hence, a fleet of motor vehicles have been arranged to transport the employees from various identified pick-up places of their location to the MWSEZ office at the above-mentioned address and drop them back from the office to these identified places. That in this connection, they have entered into contract with Transport Service Provider for providing buses for transport facilities to the employees from their respective pick-up location till the office premises and the return. The regular routes are fixed. That the applicant recover nominal amount from the employees on monthly basis. Such recoveries are shown as a deduction in the monthly pay slip of the employees. In the employment contract, the transportation details are covered under the perquisites category. The deduction amount towards applicant transportation can change subject to Company’s discretion and the same will be intimated at the time of change. That for the procurement of transportation services from the transport service provider, the company is availing Input Tax Credit on the tax charged. That the recovery made from the employees is credited to the expense account in which transportation expense is booked and debited to the salary payable account in respect of employees on the rolls of the applicant. That the services in relation to transportation through motor vehicles are provided by the Transportation Service Provider to all the employees, who have opted for such benefit from the applicant. It is agreed that the applicant shall enter into a contract and pay in full to the transportation service provider for the service provided during the prescribed period on behalf of the employees and nominal amount is recovered from the employees on a monthly basis and the balance amount is borne by the applicant. The applicant sought advance ruling on the following questions: (1) Whether the nominal amounts recovered by the applicant from employees for transportation services would be considered a “supply” under the provisions of section 7 of the CGST Act 2017. (2) In case answer to the above is “Yes” At what value, the applicant is required to remit GST? Whether on the amount recovered from the employees for the transport services provided or on the amount paid by the applicant to the Transportation Service Provider? RULING : (1) The nominal amount recovered by the applicant from the employees for arranging the transportation services through a third-party transport service provider to their employees cannot considered as “supply” under the provisions of section 7 of the Central Goods and Services Tax Act, 2017 in as much as the same does not fulfill the parameters for an activity to be considered as “supply”. (2) Since the answer to the above is not in the affirmative, the question of answering the second query, does not arise. Renault Nissan Technology & Business Centre India (P.) Ltd., In re (2026) 130 ITPJ (SG) 324 (AAR) States GST & VAT - QUESTION : Applicant is engaged in the business of precast concrete construction. The applicant makes concrete structures in their own premises by a process known as “Precasting” and then transports the structures to its customers’ sites for manoeuvring/assembling them into buildings. No actual construction takes place in the customers’ site. The applicant sought advance ruling on the following questions: (1) Whether the applicant is required to obtain registration in the states in which it is executing works contract using precast structures manufactured at its principal place of business in Tirupur, when it has no “fixed establishment” in such state? (2) Whether it is mandatory to register the site address (where there is only temporary office and no fixed establishment) as additional place of business if the site address is different from the registered office address but within the same state? (3) Whether the transportation of material used in erection of the precast structures in the construction sites in other states, amounts to supply in the absence of consideration and in the absence of two different parties involved? (4) Whether such transportation of manufactured elements and other raw materials for site work used for erection of the precast structures would require raising of invoice? (5) If invoice is not required, can the movement of goods shall be made according to rule 55(1)(c) of the CGST Rules 2017 without support of invoice but with Delivery Challan? (6) Whether it is mandatory to specify the tax rate in delivery challan (as per Rule 55(1)) since we undertake only works contract and the rate of tax for the same is 18%, but the rate of tax for individual components (like cement) is 28% when they are sold separately? (7) The delivery challan and e-way bill for manufactured elements and other raw materials for site work would contain GST rates and corresponding HSN codes, which would differ from the final invoice where SAC code for composite works contract would be mentioned. Would that be considered as a mismatch between HSN/SAC codes and GST rates in e-way bill and actual invoice, which is made at stage wise completion of construction, by the tax authorities? (8) Similarly, in cases of movement of machineries (no transfer of ownership) to work sites, where there is no permanent establishment at the respective state and only used to perform the construction service, whether the difference in HSN/SAC codes and GST rates in e-way bill and actual composite supply invoice would be considered as mismatch? (9) What document shall be issued for return of tools, equipments for return from worksite to our registered office? (10) If tools, equipments and accessories which are returnable after work execution should be transported under delivery challan, what is the rate to be adopted in the delivery challan and e-way bill, whether contract rate or whether GST rate of the tools and equipments transported? (11) If we are transferring materials and equipments between two sites at respective state where we do not have fixed establishment, what document shall be used for transportation of the same? RULING : (1) Yes, the applicant is required to get registered in the state where the construction site is located. (2) Yes, whenever, the applicant undertakes assembling of the precast structures at a construction site situated in Tamil Nadu, where the applicant has a principal place of business, they may add such sites as ‘additional places of business’. In case, the construction site is located in another state, they are required to get registered in the state where the construction site is located. (3) Yes, the transportation of material used in erection of the precast structures in the construction sites in other states amounts to supply. (4) The question is not covered under the issues mentioned under section 97(2) of the CGST Act 2017. Hence the question is liable for rejection in terms of section 98(2) of the CGST Act 2017. (5) The question is not covered under the issues mentioned under section 97(2) of the CGST Act 2017. Hence the question is liable for rejection in terms of section 98(2) of the CGST Act 2017. (6) The question is not covered under the issues mentioned under section 97(2) of the CGST Act 2017. Hence the question is liable for rejection in terms of section 98(2) of the CGST Act 2017. (7) The question is not covered under the issues mentioned under section 97(2) of the CGST Act 2017. Hence the question is liable for rejection in terms of section 98(2) of the CGST Act 2017. (8) The question is not covered under the issues mentioned under section 97(2) of the CGST Act 2017. Hence the question is liable for rejection in terms of section 98(2) of the CGST Act 2017. (9) The question is not covered under the issues mentioned under section 97(2) of the CGST Act 2017. Hence the question is liable for rejection in terms of section 98(2) of the CGST Act 2017. (10) The question is not covered under the issues mentioned under section 97(2) of the CGST Act 2017. Hence the question is liable for rejection in terms of section 98(2) of the CGST Act 2017. (11) The question is not covered under the issues mentioned under section 97(2) of the CGST Act 2017. Hence the question is liable for rejection in terms of section 98(2) of the CGST Act 2017. Teemage Builders (P.) Ltd., In re (2026) 130 ITPJ (SG) 322 (AAR) States GST & VAT - QUESTION : Applicant is engaged in the business of crafting sliver products using raw materials like silver and copper. These materials come in various purities, affecting the value of the silver bars. They purchase silver bars from vendors located outside Tamil Nadu, process them along with copper and fashion them into silver ornaments. Sometimes they also outsource these process through job work. The applicant sought advance ruling on the following questions: (1) Barter Exchange in B2B Transactions: Does barter exchange apply to B2B transactions where payments are made without the involvement of bank transactions? Specifically, is the exchange of silver scrap for finished ornaments under GST laws considered a supply, despite the absence of monetary payments? (2) Reverse Charge Mechanism (RCM) for Job Work: If Job Work is performed by an unregistered individual, does RCM apply? Additionally, does RCM cover job work provided by individuals to proprietorship concerns? (3) Shipping Label and Packaging Confidentiality: For security purposes, is it permissible to mention the legal name (PAARAGIRI BALARAMAN NAGARAJESWARAN) on shipping labels and use discreet packaging, thereby not disclosing the nature of the goods (e.g., silver ornaments) in the shipment? (4) Insurance Coverage for Goods: In cases where insurance for goods is mandatory, can the insurance coverage be based on a lesser value than the actual value of the goods? (5) HSN Codes for Silver and Scrap Products: What are the appropriate HSN codes for the following: n Silver Scrap n Melted Scrap Bars n Melted Silver Rods n Melted “Kacha” (imperfect silver)? (6) E-Way Bill Requirements for Silver Products: Is an E-way bill mandatory for purchase and sale of the following items: n Silver Scrap n Silver Ornaments n Silver Fine? (7) E-Way Bill for Delivery Challans: In what situations is an E-way bill required for goods sent under delivery challans, specifically for supply on approval, job work or repair? (8) Valuation of Products with Varying Purity: How to differentiate the value of silver products that have varying purities but are otherwise identical in name? What documentation is necessary to validate these differences in value? (9) Payment to Job Workers in Materials: Is it permissible under GST regulations to make payments to job workers in the form of materials (such as silver or copper) rather than conducting a monetary sales transactions? RULING : (1) Barter system is covered under the scope of ‘supply’ and specifically exchange of silver scrap for finished ornaments will be considered a ‘supply’ under the GST law, despite the absence of monetary payments. (2) As job-work does not attract RCM, the question of answering the said query does not arise. (3) No ruling is passed as the said question does not fit into any of the clauses at (a) to (g) of section 97 (2) of the CGST Act, 2017. (4) No ruling is passed as the said question does not fit into any of the clauses at (a) to (g) of section 97 (2) of the CGST Act, 2017, and since the same is not related to GST in any manner. (5) Silver Scrap - 7112 Melted scrap Bars - 7112 Melted Silver Rods - 7106 Melted ‘Kacha’ (Imperfect Silver) -7106 (6) E-way bill is not mandatory for the movement inter-state and intra-state involving purchase and sale of silver scrap, silver ornaments and silver fine. (7) E-way bill is not mandatory for the movement of goods in question in situations involving supply on approval, job work and repair of silver bars and ornaments. (8) No ruling is passed as the said question does not fit into any of the clauses at (a) to (g) of section 97 (2) of the CGST Act, 2017 and since the same is not related to GST (9) No ruling is passed as the said question does not fit into any of the clauses at (a) to (g) of section 97 (2) of the CGST Act, 2017. Paaragiri Balaraman Nagarajeswaran, In re (2026) 130 ITPJ (SG) 320 (AAR) States GST & VAT - QUESTION : Applicant is a privately held education institution providing education to students for competitive exams in streams such as IIT-JEE, NEET, and other competitive examinations. The institute is headquartered in Kota, Rajasthan, and operates multiple centres in Rajasthan and other States across India. Apart from offline coaching the Applicant also offers digital coaching programs through its e-learning platform, through its website and its mobile application. These programs comprise live online classes, pre-recorded courses, or a combination of both, delivered over the internet. Students pay a subscription fee to access these courses and are not required to be physically present in any classroom. Similarly, the education content available on the platform might also be streamed from a place where student may not be located. The student may be in one State, the trainer providing live online lectures may be located in any State across India, and the downloadable content (i.e. video / digital material) provided to student may be hosted on a server located in another state anywhere in India. The technology team responsible for managing and maintaining the online platform is situated in the State of Karnataka. The invoice for such services is raised to the student from the state of Rajasthan. The essential feature of the Applicant’s supply is grant of electronic access to digital educational content, enabling students located across India to learn through the online platform. The platform offers interactive classes. The applicant also sends printed study materials to enrolled students to enhance learning outcomes, which are dispatched through courier from Kota to the address provided by the students. The applicant has sought advance ruling on the following questions: (1) Whether supply of online training services (delivered through live/recorded digital platforms) shall qualify as “online information or database access retrieval service” under HSN 998433 (i.e. On-line video content) or should be covered under HSN code 999293 (i.e. Commercial Training and Coaching Services)? (2) Determination of the tax liability under the CGST and SGST Acts especially when the student is based in a state outside Rajasthan? RULING : (1) The activity carried out by the taxpayer is classified as commercial Training and Coaching services with SAC 999293. (2) In case of recipients location is available on record of the taxpayer that is outside the state of Rajasthan for receiving service of online commercial Training and Coaching SAC No. 999293 liability of the taxpayer is 9% CGST and 9% SGST. Allen Career Institute (P.) Ltd., In re (2026) 130 ITPJ (SG) 318 (AAR) States GST & VAT - QUESTION : The applicant is engaged in the manufacturing and selling of packing material i.e. carrying bag of various types. The issue raised by the applicant is fit to pronounce advance ruling as they have deposited prescribed fee under CGST Act and it falls under the ambit of the Section 97(2) given as under- classification of goods and/or services or both, and Applicability of a notification issued under the provisions of this Act. The applicant sought advance ruling on the following questions: (1) Classification/HSN: Whether the Applicant’s biodegradable bags are classifiable under Chapter 39 (if of plastic/compostable polymer) or Chapter 48 (if of paper), and the appropriate HSN therein. (2) Rate of tax & applicability of notification: Whether supplies of the said biodegradable bags are covered by the entry “Paper Sacks/Bags and bio-degradable bags” (Ch. 39, 48) in Schedule I of Notification 9/2025-CTR, attracting 5% GST (2.5% CGST + 2.5% SGST), with effect from 22-Sep-2025. RULING : (1) The bags in question, if made from polymer or compostable plastics, are classifiable under Chapter 39 - Plastics and articles thereof, specifically under heading 3923, being articles for the conveyance or packing of goods. Furthermore, if the bags are manufactured from paper, they are classifiable under Chapter 48 - Paper and paperboard; articles of paper pulp, of paper or of paperboard. This classification is independent of whether the material is biodegradable or not. (2) Accordingly, while we cannot determine whether the applicant’s product is biodegradable or compostable, we hold that if the bags supplied by the applicant are biodegradable, then the benefit of Entry No. 319 of Schedule I would be available and GST would be payable at the rate of 5% (2.5% CGST + 2.5% SGST). If the product is not biodegradable, then the concessional rate would not apply, and the applicable rate under the general classification for plastic bags under Chapter 39 would apply. Sunita Kohli, In re (2026) 130 ITPJ (SG) 317 (AAR) States GST & VAT - QUESTION : Applicant is a statutory autonomous, institution established under the Kerala Devaswom Recruitment Board Act, 2015, enacted by the Government of Kerala. The objective of the applicant is to conduct examinations for the selection of suitable candidates for appointment to various posts in five Devaswom Boards situated in different geographical areas across the State of Kerala. The applicant sought advance ruling on the following questions: (1) Whether GST Registration is to be obtained by the board? (2) Whether GST is to be collected from the application fee collected from the candidates? (3) Whether GST is applicable for the activity of conducting examination? RULING : (1) The applicant is a taxable service provider and is liable to be registered if the aggregate value of the supply of services exceeds the threshold limit prescribed under section 22 of the CGST Act, or if the applicant falls under any of the categories specified under section 24 of the Act. (2) Yes, the fees collected from candidates represent consideration for services supplied by the applicant in conducting recruitment examinations and related processes. Accordingly, they are chargeable to GST under section 9 of the CGST Act. (3) Yes. The services provided by the applicant to candidates in connection with recruitment of eligible persons to various posts in the Devaswom Boards constitute a taxable supply under section 2(108) of the CGST Act, 2017. Kerala Devaswom Recruitment Board, In re (2026) 130 ITPJ (SG) 315 (AAR) States GST & VAT - QUESTION : The applicant is engaged in the manufacture, sale and trading of automotive parts, classifiable under HSN 8708, and supplies such goods and related services to automotive Original Equipment Manufacturers (OEMs) as well as Tier-I suppliers. The applicant submits that it operates three manufacturing locations within the State of Karnataka and employs approximately 1,288 employees across all locations, excluding contract employees. The applicant is registered under the provisions of the Factories Act, 1948. The applicant has engaged Canteen Service Providers (CSPs) for providing food facilities to its employees as well as contract employees at all three locations, through canteen facilities operated within the factory premises. The applicant sought an advance ruling on the question as to whether input tax credit (ITC) is admissible to the applicant on GST charged by the CSP for providing catering services, which the applicant is mandatorily required to provide under section 46 of the Factories Act, 1948? RULING : The applicant is eligible to avail input tax credit of GST charged by the Canteen Service Provider (CSP) in respect of canteen services provided to its regular employees, in terms of the proviso to section 17(5)(b) of the CGST Act, 2017, read with Serial No. 7 of Notification No. 11/2017-Central Tax (Rate) dated 28-6-2017, as amended, and Circular No. 172/04/2022-GST dated 06-7-2022, since the provision of canteen facility is obligatory under section 46 of the Factories Act, 1948. However, the admissibility of input tax credit shall be restricted only to the extent of the cost of canteen services actually borne by the applicant. M/s. Aditya Auto Products & Engineering India Pvt. Ltd., In re (2026) 130 ITPJ (SG) 313 (AAR) States GST & VAT - QUESTION : Applicant, a government enterprise, has entered into a works order with M/s Singhal Enterprises for transforming raw limestone/dolomite extracted from its mine in Odisha into finished, marketable products through a series of processing steps: crushing, sizing, screening, and grading. The contract places complete commercial and operational risk on Singhal Enterprises until the delivery of conforming, processed limestone/dolomite. BSLC maintains the right to reject any product not meeting prescribed specifications. Crucially, raw limestone/dolomite has no direct industrial utility until subjected to these processes, substantiating the emergence of a commercially distinct commodity. Applicant sought advance ruling on the question: Whether the activity carried out by the applicant amounts to “manufacture” under section 2(72) of the CGST Act, 2017. RULING : The activity carried out by the applicant does not amount to manufacture under section 2(72) of CGST/OGST Act, 2017. Bisra Stone Lime Company Ltd., In re (2026) 130 ITPJ (SG) 312 (AAR) States GST & VAT - QUESTION : Applicant is engaged in trading business of Psyllium seeds, commonly known as Isabgol, to be purchased from farmers through auctions conducted by Agricultural Produce Market Committees (APMCs) in the State of Gujarat. The applicant proposes to supply such Psyllium seeds (Isabgol), without undertaking any processing or value addition, to Isabgol processing units and the said activities are proposed to be carried out in the ordinary course of business. The applicant is also maintaining a warehouse at its place of business which is duly registered under the Goods and Services Tax. It sought advance ruling on the following questions: (1) Whether Psyllium Seeds (Isabgol) supplied in their natural, raw and unprocessed form as procured through Agricultural Produce Market Committee (APMC) auctions directly from farmers, without undergoing any drying, freezing, crushing or other processing qualifies as “fresh” Isabgol seeds and are exempted under Entry 87 (HSN 1211) of Notification No. 10/2025-Central Tax (Rate) dated 17-9-2025 as “Plants and parts of plants (including seeds and fruits) of a kind used primarily in perfumery, in pharmacy or for insecticidal, fungicidal or similar purpose, fresh or “chilled”? (2) Alternatively, whether Psyllium Seeds (Isabgol) as discussed above qualifies as “goods of seed quality” and are exempt from GST under Entry 77 (HSN 12) of Notification No. 10/2025-Central Tax (Rate) dated 17-9-2025? RULING : (1) Yes, Psyllium Seeds (Isabgol) supplied in their natural, raw and unprocessed form as procured through Agricultural Produce Market Committee (APMC) auctions directly from farmers, without undergoing any drying, freezing, crushing or other processing qualifies as “fresh” Isabgol seeds and are exempted under Entry 87 (HSN 1211) of Notification No. 10/2025-Central Tax (Rate) dated 17-9-2025 as “Plants and parts of plants (including seeds and fruits) of a kind used primarily in perfumery, in pharmacy or for insecticidal, fungicidal or similar purpose, fresh or “chilled.” (2) No. in view of answer to Question 1. M/s. Jigneshkumar Narayandas Patel (Trade Name: Akshar Traders), In re (2026) 130 ITPJ (SG) 310 (AAR)