The Applicant, ARG Electricals Pvt. Ltd. has received work orders from Ajmer Vidyut Vitran Nigam Limited (AVVNL)  through a tender process. The work orders are awarded to them through a tender and scope of work is described in respective work orders as submitted with application. The two work orders as awarded through the tenders are “Supply of material/equipment for providing of Rural Electricity Infrastructure for Household electrification in selected blocks under Rajiv Gandhi Grameen Vidyutikaran Yojana scheme on turnkey basis”, and Erection, testing and commissioning supplied material/equipment for Rural Electricity Infrastructure for Household electrification in selected blocks under Rajiv Gandhi Grameen Vidyutikaran Yojana scheme on turnkey basis”, the two work orders separately describes each activity to be carried out to complete the work and also rate for each activity is separately mentioned, by adding amount of each activity total cost is derived.

The applicant sought the advance ruling on the issues whether the contract entered into with AWNL as per the work orders combine of supply, erection, testing and commissioning of materials/equipment for providing rural electricity infrastructure qualifies as a supply for work contract under Section 2(119) of CGST Act.

It was further asked whether such supply, erection, testing and commissioning of materials/equipment for providing rural electricity infrastructure made to AWNL would be taxable at the rate of 12% in terms of Sr. No. 3(vi)(a) of the Notification No. 11/2017- Central Tax (Rate) dated June 28, 2017 as amended w. e. f. January 25, 2018.