The Gujarat Authority of Advance Ruling (AAR) ruled that GST is applicable on supply of Aluminium Foil Type Winding Inverter Duty Transformer.
The applicant, M/s. Silcher Technologies Ltd. is one of India’s prominent manufacturers of Electronics and Telecom and Power & Distribution transformers. The said company was founded in 1990 to manufacture R-core transformers. In 1995, after an overwhelming response from the market, they ventured into the manufacturing of Ferrite transformers. As part of their expansion plans, they started manufacturing Distribution and Power Transformers in a phased manner from 2005 to 2007. The applicant now caters to a wide cross section of industrial segments from utility to renewable energy sector and to individual retail customers across the globe.
The applicant submitted that they provide an extensive range of Linear Transformers from R-core to EI and Toroidal to Current transformers. These transformers can be supplied according to customer specific requirements in terms of thermal insulation, cut-offs, static-magnetic shielding, special mounting, epoxy moulding, vacuum impregnation, etc.
The applicant has sought the advanced ruling on the issue 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. 01/20017-Central Tax (Rate) dated 28th June, 2017 and liable to Central GST at the rate of 2.5% along with State GST at the rate of 2.5%.
The coram of Sanjay Saxena and Mohit Aggarwal ruled that the applicant is liable for payment of GST on the total value of both the Purchase Order i.e. supply of goods and supply of service in terms of Explanation inserted vide Entry No. 234 of Not. No. 01/2017-CT (Rate) dated 28.06.2017 vide Notification No. 24/2018- CT (Rate) dated 31.12.2018. 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.
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