Rate of tax (service)— The present appeal has been filed against an advance ruling order.

In view of the above, the advance ruling was sought by the appellant as under:-

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. 01/2017-Central Tax (Rate) dated 28,h June, 2017 and liable to Central GST 2.5% along with State GST at the rate of 2.5%.

The Gujarat Authority for Advance Ruling, held as follows—

The appellant 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 Noti. 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.

Held that— This authority modify the Advance Ruling of the Gujarat Authority for Advance Ruling in the case of M/s. Shilchar Technologies Limited to the following extent-

(i) The appellant is liable for payment of GST on the total value of both the Purchase Order i.e. supply of goods and supply of services in terms of Explanation inserted vide Entry No.234 to Notification No. 01/2017- Central Tax (Rate) dated 28.06.2017 vide Notification No. 24/2018-Central Tax (Rate) dated 31.12.2018

(ii) Thereafter the same will be covered under entry Sr.No. 201A appearing under Schedule-II to the Notification No.01/2017-Central Tax (Rate) dated 28.06.2017 amended vide Notification No. 08/2021-Central Tax (Rate) dated 30.09.2021 and liable to be taxed w.e.f. 01.10.2021 as under. 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. Accordingly, the effective rate comes to 13.8%.