Classification of supply— the applicant, seeking an advance ruling in respect of the following questions.

I. Whether the transaction/ contract referred in the present application to M/S APTRANSCO is in the nature of Works Contract Services and therefore liable to GST @ 18% under the HSN Code 995461 ?

II. If the answer to above is in negative, whether the said transaction is Supply of Goods ?

a) If yes, liable to GST at what rate of tax and under which HSN Code ?

Held that—
we find that the goods that are supplied are used by the applicant to provide services installation, testing and commissioning of the substations. Without these goods the services cannot be supplied by the applicant and therefore we find that the goods and services are supplied as a combination and in conjunction and in the course of their business where the principal supply is supply of goods. Thus we find that there is a composite supply in the subject case since in the subject case there is no building, construction, fabrication, completion, erection, installation, fitting out, improvement, modification, repair maintenance, renovation, alteration or commissioning of any immovable property wherein transfer of property in goods (whether as goods or in some other form) is involved in the execution of the contract.

The said transaction is a composite supply where the principal supply majorly is a supply of goods

a) On the basis of submissions made by the applicant we find that the entire transaction is taxable @18 GST under Heading 8537 of the GST Tariff.— NR Energy Solutions India Pvt. Ltd., In Re… [2019] 08 TAXLOK.COM 106 (AAR-Maharashtra)