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The GAAR held that specially designed transformers for WOEG performing dual step-down and step-up functions, supplied by the appellant along with WOEG, cannot be treated as part of WOEG. This is based on CBIC's circular excluding transformers from WOEG parts as per Ministry of New and Renewable Energy's clarification. The appellant's reliance on popular meaning/common parlance principle and Enercon India Ltd's case was rejected as legally untenable. Consequently, such transformers are ineligible for exemption under Sr. No. 234 and 201A of Notification No. 1/2017-CT (Rate). The appeal was dismissed.
The GAAR held that specially designed transformers for WOEG performing dual step-down and step-up functions, supplied by the appellant along with WOEG, cannot be treated as part of WOEG. This is based on CBIC's circular excluding transformers from WOEG parts as per Ministry of New and Renewable Energy's clarification. The appellant's reliance on popular meaning/common parlance principle and Enercon India Ltd's case was rejected as legally untenable. Consequently, such transformers are ineligible for exemption under Sr. No. 234 and 201A of Notification No. 1/2017-CT (Rate). The appeal was dismissed.
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