2019-VIL-76-MAD-CE

SGST Advance Ruling Authority

GST – Telangana AAR - Applicant entered into contract with South Central Railway for design, supply, installing, testing & commissioning of train collision avoidance system in locomotives (TCAS equipment) - as per the agreement applicant shall supply multiple items and provide various services including annual maintenance services with the service code 9954 - whether supply of the applicant falls within the scope of composite supply of works contract service defined under Section 2(119) of the CGST Act and accordingly chargeable to 12% GST – HELD - the contract is for design, supply, installation, testing and commissioning of onboard TCAS equipment in locomotives and track side - the entire system is based on signaling equipment and RFID tags. The principal goods in the system is electrical signaling equipment enumerated as HSN 8530 i.e., ‘Electrical signaling, safety or traffic control equipment for railways, tramways, roads, inland waterways, parking facilities, port installations or airfields’ - supply of subject system is a naturally bundled supply of various goods working in unison to achieve a single purpose of railway safety through signaling etc., Therefore the supply of this system to Indian Railways under a contract has all the attributes to make it a composite supply and the rate of tax applicable is the rate at which the principal supply has to be taxed i.e., Electrical signalling equipment with HSN code ‘8530’ - the supply of Train Collision Avoidance System (TCAS) is taxable at 18% GST

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