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GST – Gujarat AAAR - Whether the benefit of concessional rate of GST in terms of Sr. No. 234 of Schedule-I to Notification No. 1/2017-IT (Rate) dated 28.06.2017 is applicable to the HT/LT XLPE Cables designed, manufactured and supplied by the appellant for use as parts in the manufacture of Solar Power Generating System/ Solar Power Projects – HELD - the purchase orders placed with appellant involve only supply of goods and does not involve any kind of service – scope of services essential for manufacturing of goods as per buyer’s specification and make the goods marketable is not beyond the sale of goods and that there is no element of ‘works contract service’ involved or performed by appellant as sub-contractor to the Solar Power Generating System - Therefore, amendment made to Sr.234 of Notification No. 01/2017-Integrated Tax (Rate) vide Notification No. 25/2018- Integrated Tax (Rate) dated 31.12.2018 and Notification No. 28/2018-Integrated Tax (Rate) dated 31.12.2018, for deciding value of services and rate of GST thereon, will not be applicable as there is no provision of service supplied by the appellant with respect to Solar Power Generating System - The product Solar HT/LT XLPE Cables to be used in the manufacture of Solar Power Generating System/ Solar Power Generator is eligible for benefit of Entry at Sr. No. 234 under Schedule-I of Notification No.01/2017-Integrated Tax (Rate) dated 28.06.2017 and liable to be taxed at 5% GST upto 30.09.2021 and thereafter under Entry at Sr.No.201A of Schedule-II of Notification No.01/20I7-IT (Rate) dated 28.06.2017 amended vide Notification No. 08/2021-IT (Rate) dated 30.09.2021 and liable to be taxed at 12% GST w.e.f. 01.10.2021 - Order passed by Authority for Advance Ruling is modified
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