In Advance Ruling No. UP ADRG 27/2023 -AAR- AAR (Uttar Pradesh) rules 'Solar Home Lighting System' falls under 'Solar Power-Based Devices' & taxable at 12% GST
Members Rajendra Kumar (Central Tax) & Harilal Prajapati (State Tax) [08-05-2023]

Read Order: In Re:  R2V2 Technologies Private Limited

Chahat Varma

New Delhi, July 27, 2023: The Uttar Pradesh Authority for Advance Rulings has issued a ruling stating that the 'Solar Home Lighting System', which R2V2 Technologies Private Limited (applicant) intended to supply, fell under the category of 'Solar power-based devices' as specified in Entry No. 201A of Schedule II of Notification No. 1/2017-Central Tax (Rate), dated 28th June 2017, as amended vide Notification No. 8/2021-Central Tax (Rate).

In the said case, the applicant had sought an advance ruling regarding the classification of their intended supply of Solar Home Lighting System. Specifically, they had sought clarification on whether this supply of goods fell under the category of 'Solar power-based devices' as mentioned in Entry No. 201A of Schedule II of Notification No. 1/2017-Central Tax (Rate), dated 28th June 2017, as amended vide Notification No. 8/2021-Central Tax (Rate).

The two-member bench of Rajendra Kumar (Central Tax) and Harilal Prajapati (State Tax) considered the classification of the Solar Home Lighting System and applied the principle that the heading which provides the most specific description should be preferred over headings providing a more general description. Additionally, in cases where two or more headings referred to only part of the materials or substances contained in mixed or composite goods, they were to be considered equally specific in relation to those goods. Based on this analysis, the bench held that the Solar Home Lighting System should be classified under heading 94055040. Consequently, this product was deemed taxable under GST at a rate of 12%.