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    <title>2026 (2) TMI 647 - AUTHORITY FOR ADVANCE RULING, TAMILNADU</title>
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    <description>A Battery Energy Storage System that stores electricity by converting it into chemical energy and re-delivers it on demand was held not to be generation, transmission or distribution of electrical energy. On that basis, standalone BESS did not qualify for GST exemption on supply of electricity. The same reasoning was applied to co-located BESS: co-location changed the physical arrangement, not the essential storage function, so exemption or nil rate treatment under the cited notifications was unavailable. The activity was instead classified as support services to electricity transmission and distribution, taxable at 18%, and GST registration in Tamil Nadu was required for the taxable supplies made there.</description>
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      <description>A Battery Energy Storage System that stores electricity by converting it into chemical energy and re-delivers it on demand was held not to be generation, transmission or distribution of electrical energy. On that basis, standalone BESS did not qualify for GST exemption on supply of electricity. The same reasoning was applied to co-located BESS: co-location changed the physical arrangement, not the essential storage function, so exemption or nil rate treatment under the cited notifications was unavailable. The activity was instead classified as support services to electricity transmission and distribution, taxable at 18%, and GST registration in Tamil Nadu was required for the taxable supplies made there.</description>
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