AAR held that rooftop solar supply under the power purchase...

AAR held that rooftop solar supply under the power purchase arrangement was a supply of electrical energy, with the plant remaining the applicant's asset during the contract term. Electrical energy was treated as exempt goods, so the applicant was supplying only wholly exempt goods and, under Section 23, was not required to obtain GST registration. The Authority added that this exemption would not apply if taxable goods or services were supplied alongside electricity, or if taxable inter-State supplies were made. It also held that an advance ruling binds only the applicant and the relevant officers under Section 103, and only while the same law, facts and circumstances continue.