Transfer-pricing aggregation of distinct support-service and subcontract transactions was rejected, while debt-free receivables attracted no notional ...
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Battery energy storage systems (BESS) are characterised as storage facilities that convert electrical energy to chemical energy and back, and therefore are not generation, transmission or distribution utilities; accordingly, exemption notifications for generation/transmission/distribution do not apply, whether BESS is standalone or co located. The activity of developing and operating BESS does not amount to supply/generation of electricity for the notified exemptions, so those nil rate/exemption entries are inapplicable. The service is classifiable as support services to electricity transmission and distribution (HSN 998631), liable to GST at 18%, and the operator must register for GST in Tamil Nadu if the BESS is established there.
Battery energy storage systems (BESS) are characterised as storage facilities that convert electrical energy to chemical energy and back, and therefore are not generation, transmission or distribution utilities; accordingly, exemption notifications for generation/transmission/distribution do not apply, whether BESS is standalone or co located. The activity of developing and operating BESS does not amount to supply/generation of electricity for the notified exemptions, so those nil rate/exemption entries are inapplicable. The service is classifiable as support services to electricity transmission and distribution (HSN 998631), liable to GST at 18%, and the operator must register for GST in Tamil Nadu if the BESS is established there.
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