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Composite Supply of works contract for Construction of tunnel covered under Entry 3(iv) of Notification No. 11/2017-CT (Rate) dated 28.06.2017 taxable at the rate of 12%

Classification of service— The present application has been filed by the applicant seeking an advance ruling in respect of the following question— 

1. Whether the activity to be carried by the applicant shall be classified as supply of goods or services or a composite supply of ‘works’ contract’?

2. Whether the activity should be classified as Composite Supply of works contract for Construction of tunnel under Entry 3(iv) of Notification No. 11/2017-CT (Rate) dated 28.06.2017 taxable at the rate of 12%?

The Applicant is engaged in drilling and blasting works at various sites using Industrial explosives and other materials.

The work awarded to the main contractor viz. NECL is, construction of Tunnel and Approach roads. In order to complete the said EPC contract, the main contractor has engaged the applicant as a sub-contractor for drilling and blasting work for rock tunneling. The applicant has submitted the general cycle of drilling and blasting activity in their submissions.

Held that— The impugned activity carried out by the applicant is a ‘composite supply’ of works contract.

The activity should be classified as Composite Supply of works contract for Construction of tunnel under Entry 3(iv) of Notification No. 11/2017-CT (Rate) dated 28.06.2017 taxable at the rate of 12%.

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