GST Ruling: 6% Tax Rate for Stator Coils in Wind Generator Production

The Authority for Advance Ruling determined that the supply of stator coils to a manufacturing company for the production of Wind Operated Electricity Generators qualifies for a 6% CGST and 6% SGST rate under specific GST notifications. The ruling is subject to the supplier's self-assessment that all supplies are for renewable energy generator manufacturing, supported by relevant purchase orders and supply contracts.

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Issues Involved:
1. Applicability of GST rate on the supply of Stator Coil.
2. Interpretation of relevant GST notifications and circulars.
3. Documentary evidence required to claim concessional GST rate.

Issue-wise Detailed Analysis:

1. Applicability of GST rate on the supply of Stator Coil:
The applicant, Coral Coil India Private Limited, sought an advance ruling on whether the supply of Stator Coil to Coral Manufacturing Works India Private Ltd. would be eligible for a 2.5% CGST and 2.5% SGST as per SI. No. 234 in the notification 1-CTR dated 28 June 2017. The applicant later modified the question to whether the supply would be eligible for a 6% GST rate as per SI. No. 201A in the Schedule II of the same notification, as amended by Notification No. 8 CTR dated 30 September 2021.

2. Interpretation of relevant GST notifications and circulars:
The applicant referenced Circular No. 80/54/2018 GST dated 31.12.2018, which clarifies that GST is to be self-assessed by the taxpayer. The supplier needs to satisfy himself with the requisite document from the buyer, such as supply contracts/orders for WTEP, before supplying goods claiming concession under the specified entry. The applicant also noted that the stator coils fall under tariff item 85030010 and are parts for the manufacture of Wind Operated Electricity Generators (WOEG).

3. Documentary evidence required to claim concessional GST rate:
The applicant provided purchase orders and a generator supply agreement to demonstrate that the stator coils are for use in WOEG. The State Jurisdictional Authority noted that the product might be used in manufacturing ordinary generators or WOEG, and specified scenarios where different GST rates would apply (5% or 18%). The authority emphasized the need for the supplier to obtain and verify requisite documents from the buyer to claim the concessional rate.

Judgment Summary:
The Authority for Advance Ruling examined the submissions, additional documents, and remarks from the jurisdictional authorities. It was determined that the supply of stator coils to Coral Manufacturing Works Pvt Ltd. for the manufacture of WOEGs qualifies for the 6% CGST and 6% SGST rates as per SI. No. 201A of Schedule II to Notification No. 01/2017-CT (Rate) dated 28.06.2017, as amended. The ruling is subject to the applicant's self-assessment that all such supplies are for the manufacture of generators for renewable energy, based on purchase orders and supply contracts.

Ruling:
The supply of Stator Coil by the Applicant to Coral Manufacturing Works India Private Limited for use in WOEG will be eligible for the levy of 6% CGST and 6% SGST effective from 01.10.2021, subject to self-assessment by the applicant that all such supplies are for the manufacture of generators for renewable energy, based on the purchase orders/supply contracts for each supply.

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