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2018 (11) TMI 401 - AAR - GSTClassification of manufactured item - items used for manufacture of Solar Cells - whether parts for manufacture of Photovoltaic Cells/Solar Cells to be covered under Entry 234 of Schedule-I of Notification No. 1/2017-Integrated Tax (Rate), dated 28-6-2017 or not? Held that:- It is clear from the whole manufacturing process that silicon wafer is the most important input for the manufacture of solar cells which is treated with the various chemicals during the different steps of texturization, diffusion, junction edge isolation anti-reflection coating, etc. The various chemicals used during the manufacturing process have been specified in Table A from Sr. No. 2-13. These chemicals, though used in the process, yet get consumed & lose their independent identity'. To qualify as being part of the product for the purpose of aforesaid notification, the item should maintain substantial independent physical identity as when it is used in the final product. All these items mentioned in Table A from Sr. No. 2-13, instead of being treated as parts for the purpose of Entry 234 of the Notification No. 1/2017-IGST (Rate), can only be treated as inputs and do not qualify as parts for the manufacture of Photovoltaic/ solar cells. Ruling:- The items used for manufacture of solar cells as listed in Table A, procured by the applicant do not qualify to be termed as 'Parts for the manufacture of Photovoltaic/ Solar cells' for the purpose of Entry 234 of Schedule-I of Notification No. 1/2017-lntegrated Tax (Rate), dated 28-6-2017.
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