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of AAAR ruled that in a lumpsum turnkey EPC contract between Company A and Company B, the contract cannot be legally divided into separate parts despite high seas sale (HSS) of goods. The contract was deemed indivisible as the appellant was contractually obligated to provide both goods and services. While HSS transactions are neither supply of goods nor services under Schedule III of CGST Act, the value of imported goods sold on HSS basis must be included in the transaction value for GST calculation under Section 15. The AAAR rejected appellant's reliance on BSNL and Gannon Dunkerley precedents, affirming that the contract's integrated nature requires inclusion of HSS goods value in overall GST computation. Appeal dismissed.
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