Classification of service— In the instant case, the applicant is engaged in the business of water treatment, waste-water treatment and its recycling. 

the Applicant has entered into an EPC contract with M/s. Vedanta Limited. The applicant has contended that under the EPC contract they are providing Engineering, Procurement and construction (EPC) services in relation to the construction of 'Sulphate Removal Plant' for Vedanta in the state of Rajasthan.

QUESTIONS ON WHICH THE ADVANCE RULING IS SOUGHT IS AS FOLLOWS—

1. With the introduction of Notification No. 20/2019-Central Tax (Rate) dated 30.09.2019, the applicant intends to ascertain whether the services with respect to EPC contract entered for execution of Sulphate Removal plant supplied to M/s Vedanta Ltd vide Contract no 4600008952 dated 14.08.2018 is covered under Sr. No. 24(ii) (Support Services to Mining) or Sr. No. 21(ia) (Professional, Technical or Business Service to Mining) of the Rate Notification.

2. Further, if the subject services are not classifiable under any of the aforesaid entries, what would be the appropriate classification for the same and at what rate GST would be imposable?

Services provided under EPC contract awarded to the applicant by M/S Vedanta for setting up of a 'Sulphate Removal Plant' broadly ranging from designing, engineering, Surveys, procurement, fabrication, manufacturing, erection & installation, facilities construction, Pre commissioning & Commissioning, training etc. and satisfactory hand over of complete 'Sulphate Removal Plant' as per contract, it is a “work contract” of composite supply. 

Held that— The activities of supply designing & engineering, installation, Commission of Project under EPC contract by the applicant shall attract GST @18% under S.No. 3 Heading 9954 (ii) of the Notification No 11/2017 Central Tax (Rate) dated 28.06.2017.