Classification of service— In the instant case, the applicant is a company registered Linder the Indian Companies Act, 1956. It is a subsidiary of L&T Limited, an Indian technology, engineering, construction, manufacturing and financial services conglomerate. The Applicant is engaged in the business of engineering, procurement fabrication, construction and project management providing integrated solutions to the Hydrocarbon Industry. 

QUESTIONS ON WHICH THE ADVANCE RULING SOUGHT IS AS FOLLOWS—

a Whether the services provided by the Applicant are classified under Sr. No. 24(H) of Heading 9986 of Notification No. 11/2017-Central Tax (Rate) dated 28.06.2017 as 'Support services to exploration, mining or drilling of petroleum crude or natural gas or both' and attracts GST @ 12%.

b Whether, the services provided by the Applicant are classified under 'Other professional, technical and business services relating to exploration, mining, or drilling of petroleum crude or natural gas or both' under Sr. No 21(ia) of Heading 9983 of Notification No. 11/2017 - Central Tax (Rate) dated 28.06.20/7 and attracts GST a 12%.

c. 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?

We find that services provided under EPC contract awarded to the applicant by M/S Vedanta for setting up of a project broadly ranging from designing, engineering, procurement, fabrication, manufacturing assembly, erection & installation, facilities construction, insulation, dismantling, Pre commissioning & Commissioning training etc. and satisfactory hand over of complete various infrastructure facilities all customised 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.