Classification of service— In the instant case, the applicant is is a partnership firm engaged in undertaking multidisciplinary projects on turnkey basis for Power Plants, Industrial Plants, Cement Industries, Fertilizer Industries, Mining Industries, Steel Pl ants & Oil Refineries.

The applicant has to undertake a supply in respect of a tender floated by Water Resources Department, a unit of Government of Rajasthan for Survey, Investigation, designing & detail Planning, including Land acquisition (Private and Forest) process for pressurized Irrigation (Sprinkler System) including Construction of Intake well, Pump House, Panel Room and Supply, Erecting/Laying, Testing Commissioning Submerge V.T. Pumps, Rising Mains, Distribution network of Pipe Line at Chaks, O&M for Eight years including installation of Solar Power unit of 5x100 KW capacity, EPC contract on turnkey basis.

This advance ruling is sought in respect of the following question:

Considering the construction and installation of solar power unit as a part of the EPC contract and the fact that the irrigation system has to be operated on solar power, what will be the rate of tax applicable on supply of goods and services involved in the whole contract to be undertaken on turnkey basis?

As per tender document the setting up the irrigation project including Construction of Intake well, Pump House, Panel Room and Supply, Erecting/Laying, Testing Commissioning Submerge V.T. Pumps, Rising Mains, Distribution network of Pipe Line at Chaks, O&M for Eight years including installation of Solar Power unit of 5x100 KW capacity, EPC contract on turnkey basis by the applicant is a Works Contract of Composite Supply. 

Held that— This composite supply is a mixed of goods and services. Since this supply is undertaken for a Water Resources Department, a unit of Government of Rajasthan, hence shall attract GST @12% (6% CGST and 6% SGST) under S. No. 3 (Heading 9954) (iii) of Notification No. 11/2017, dated 28.06.2017.