Waste-to-energy GST classification requires reliable technical proof; boilers and heaters used with mixed fuels did not qualify.

Boilers and thermic fluid heaters claimed as waste-to-energy or renewable energy devices did not qualify for concessional GST because the petitioner failed to produce reliable technical material showing exclusive design for energy recovery from waste. The authorities relied on the petitioner's own product literature and website descriptions, which showed use with coal, rice husk, lignite, wood and briquette, undermining the claimed classification. The phrase "waste to energy plants/devices" was treated as covering systems recovering energy from agricultural, industrial or urban waste in forms such as biogas, bio-CNG or electricity, not equipment merely generating steam or heat. The writ challenge failed, as limited judicial review did not justify interference with concurrent findings absent infirmity in the decision-making process.

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Issues: Whether biomass fired steam boilers and agro waste thermic fluid heaters were eligible for concessional GST as waste to energy plants or renewable energy devices under the relevant rate notification.

Analysis: The petitioner failed to place reliable documentary material before the advance ruling authorities to establish that the disputed products were exclusively designed to generate energy from waste in the manner contemplated by the notification. The authorities found from the petitioner's own product literature and website material that the relevant boilers and heaters were described with fuels such as coal, rice husk, lignite, wood and briquette, and therefore the claimed classification as waste to energy plants was not substantiated. The phrase "waste to energy plants/devices" was held to denote plants for recovery of energy in the form of biogas, bio-CNG or electricity from agricultural, industrial or urban waste, and not boilers or heaters that merely generate steam or heat. The Court also held that the limited scope of judicial review did not justify interference with the concurrent findings of the statutory authorities on the decision-making process.

Conclusion: The goods were not entitled to the concessional GST entry claimed by the petitioner and the challenge to the advance ruling orders failed.

Ratio Decidendi: A product will qualify as a waste to energy device only if it squarely answers the description in the notification on the basis of reliable technical evidence, and the writ court will not disturb concurrent advance ruling findings absent any infirmity in the decision-making process.

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