2018 (12) TMI 844 – AUTHORITY FOR ADVANCE RULING, MAHARASHTRA – TMI – Classification of services – Rate of GST – Composite supply of works contract – MEP activities (Mechanical, Electrical & Plumbing Works) undertaken by the Applicant – whether taxable at 12% or otherwise? – benefit of Central Tax (Rate) Notification No. 01/2018 dated 25th January 2018 – supplies are in relation to an housing project enjoying Infra status – F No 13/6/2009-INF dated 30th March 2017 of Government of India – compete installation testing and commissioning and satisfactory handing order of substation electrical works, HT & LT cabling works, DG and cabling works, street light and cabling.
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Held that:- The contract like the one at hand which includes Design, engineering, work laying of RCC Hume pipe/GI pipe etc. for storm waterline and construction of chambers involves more than two taxable supplies in the nature of resources, material and machinery – large number of service receivers of such bundle of
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tract pertaining to immovable property within the scope of section 2(119) of the GST Act.
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Compete installation testing and commissioning and satisfactory handing order of substation electrical works, HT & LT cabling works, DG and cabling works, street light and cabling – Held that:- The applicant would be required to do various acts which includes design, supply, installation and commissioning of substation that is electrical infrastructure. This is also a turnkey project contract like plumbing contract discussed in the earlier part of this ruling – electrical contract which involves supply of taxable goods and services is a composite supply as defined u/ s 2(30) of the GST Act and the said composite supply is works contract as defined u/ 2(119) Of the CST Act.
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Rate of GST – MEP (Mechanical, Electrical & Plumbing Works) activities by availing the benefit of Central Tax (Rate) Notification No 01/2018 dated 25th January 2018 – taxable at 12% or not? – Held that:- The applican
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S PVT LTD, the applicant, seeking advance ruling respect of the following questions. 1) Whether MEP activities (Mechanical, Electrical & Plumbing Works) undertaken by the Applicant falls within the definition of composite supply of works contract as defined under Section 2(119) of CGST Act?? 2) Whether can the applicant charge GST rate of 12% on MEP (Mechanical, Electrical &Plumbing Works) activities by availing the benefit of Central Tax (Rate) Notification No. 01/2018 dated 25th January 2018, if the said supplies are in relation to an housing project enjoying Infra status vide F No 13/6/2009-INF dated 30th March 2017 of Government of India, in Ministry of Finance, Dept. of Economic Affairs? At the outset, we would like to make it clear that the provisions of both the CGST Act and the MGST Act are the same except for certain provisions. Therefore, unless a mention is specifically made to such dissimilar provisions, a reference to the CGST Act would also mean a reference to the
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de MEP services for an affordable housing project. The said housing project satisfies the definition of affordable housing described in Notification no 13/6/20091NF dated 30th March, 2017 by Ministry of Finance, Department of Economic Affairs thereby enjoying the Infra status within the meaning of Central Tax (Rate) Notification No. 01/2018 dated 25th January 2018. By conjoint reading of Notification No 20/2017-Central Tax (Rate) dated 22nd August 2017 and notification No 01/2018 dated 25th January 2018 as amended by inserting therein in Item No (v) new sub item (da) it is apparent that Composite supply of works contract as defined in clause (119) of section 2 of the Central Goods and Services Tax Act, 2017, supplied by way of construction, erection, commissioning, or installation of original works pertaining to, (da) low-cost houses up to a carpet area of 60 square meters per house in an affordable housing project which has been given infrastructure status vide notification of Governm
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te supply of Works contract? In reply to the above we state that, as per the draft contracts agreement for Electrical & Plumbing works to be undertaken by us and submitted in this behalf to the GST Dept. on 08.08.2018, the scope of work for electrical contract includes complete installation, testing & Commissioning of Substation Electrical Work, HT & LT Cabling work, DG & Cabling Work, Street light & Cabling Works whereas the scope of work for plumbing contract includes complete external plumbing work, laying of RCC hume pipes/Gl pipes/UPVC Pipes for storm water lines, construction of chambers. With reference to section 3(26) of General Clause Immovable Property is defined as Land, benefits to arise out of land, and things attached to the earth or permanently fastened to anything attached to the earth. Further Works Contract as defined in clause (119) of Section 2 of the CGST Act 2017, means a contract for building, construction, fabrication, completion, erection, i
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nary course of business, and hence they together form a composite supply within the meaning of Section 2 (30). B) In reply to second question on whether can the applicant charge GST Rate of 12% on MEP activities by availing the benefit of central tax rate Notification No 01/2018 dated 25th January, 2018 under sub item (da) in item (V) under serial no 3 of the said notification, the department replied that the benefit of this notification is in respect of Original Works and the same is defined under S no 2(zs) of Notfn No 12/2017 CT(rate) dated 28.06.2017 as under Original Works means-all new constructions; l) All types of additions & alterations to abandoned or damaged structure on land that are required to make them workable; Il) Erection, commissioning or installation of plant, machinery or equipment or structures, whether pre-fabricated or otherwise. The department s contention is that the aforesaid activities cannot be termed as Original Works which is impractical. All the abov
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s Tax Act, 2017, supplied by way of construction, erection, commissioning, or installation of original works pertaining to, (a) Railways, including monorail and metro; (vide notification No. 1/2018 central Tax rate dated 25/01/2018 excluding deleted and replaced by including) (b) A single residential unit otherwise than as a part of a residential complex; (c) low-cost houses up to a carpet area of 60 square meters per house in a housing project approved by competent authority empowered under the Scheme of Affordable Housing in Partnership framed by the Ministry of Housing and Urban Poverty Alleviation, Government of India; (d) Low cost houses up to a carpet area of 60 square meters per house in a housing project approved by the competent authority under (1) The Affordable Housing in Partnership component of the Housing for All (Urban) Mission/ Pradhan Mantri Awas Yojana; (2) Any housing scheme of a State Government; (e) Post-harvest storage infrastructure for agricultural produce inclu
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course of business, one of which is a principal supply; Illustration:- Where goods are packed and transported with insurance, the supply of goods, packing materials, transport and insurance is a composite supply and supply of goods is the principal supply. b) Works Contract as defined in clause (119) of section 2 of the Central Goods and Services Tax Act, 2017, the term works contract means a contract for building, construction, fabrication, completion, erection, installation, fitting out improvement, modification, repair, maintenance, renovation, alteration or commissioning of any immovable property wherein transfer of property in goods (whether as goods or in some other form) is involved in the execution of such contract. c) The definition of Original Works as defined in at S. No. 2(zs) of Notification No. 12/2017-Central Tax(rate) dated 28 06.2017 is as under; Original Works means- all new constructions; I) all types of additions and alterations to abandoned or damaged structures on
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inition of Immovable property as defined u/Section 3(26) of the General Clause, Immovable property shall include land, benefits to arise out of land, and things attached to the earth or permanently fastened to anything attached to the earth. If the aforesaid works become immovable property as permanently fastened to the building attached to Earth & transfer of property is involved in execution of contract then it will fall within the definition of Works Contract. In the opinion of this office as per the definition of composite Supply in the instant case two or more works contract supplies which are naturally bundled and supplied in conjunction with each other in the ordinary course of business, one of which is a principal supply has to be made by the applicant. So if the combination of the services provided by the applicant are covered under the definition of works contract and simultaneously is also covered under the definition of composite supply then it will fall within the defi
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Original Works viz. New construction or addition / alteration to abundant or damaged structure on land or erection commissioning or installation of plants, machinery or equipment or structure whether pre-fabricated or otherwise. Hence, prima facie, it appears that the applicant is not entitled to avail the exemption GST rate of 12% on MEP activity. Therefore, if the combination of the services provided by the applicant are covered under the definition of works contract and simultaneously is also covered under the definition of composite supply then only the applicant will be eligible to charge CST rate of 12% on MEP by availing the benefits of Central Tax-Rate Notification No. 01/2018 dated 25th January 2018 subject to fulfilment of other conditions of the notification. Additional submissions given by the Officer- Please refer to this office letter of even no. dated 30.07.2018 and letter dated 14.08.2018 received from M/s. Eiffel Hills and Dales Developers Pvt. Ltd. on the above menti
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ontract, for the proposed substation electrical works, HT & LT Cabling works, DG & Cabling works, Street Light & Cabling. a. Basic rate for each item is mentioned in Annexure-II. In case of any deviation in specification, Contractor has to seek prior written approval from Client. b. Contract shall submit all the quotes from Vendors to our Purchase dept. c. Purchase Dept. shall verify and approve the rate of the item. d. After, the above approval Contractor shall procure and install the item at site. e. Contractor shall raise bill for the same item with basic landed approved rate (excluding GST) plus 5% for handling charges. f. It shall be mandatory for the Contractor to seek approval from the client for each & every lot of Procurement of all the items & also for which the basic rates has been mentioned in Annexure-II. g. Any variations in the basic rates of the items will be paid or debited – as the case may be – to the Contractor accordingly upon the completion of
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te Supply means a supply made by a taxable person to a recipient comprising two or more supplies of goods or services, or any combination thereof, which are naturally bundled and supplied in conjunction with each other in the ordinary course of business, one of which is a principal supply. There are following elements to be present to qualify as such for composite supply 1. There should be two or more taxable services. 2. They should be naturally bundled. 3. Supply in conjunction with each other, 4. in the ordinary course of business; 5. one of which is a principal supply. It is observed that in the ordinary course of business , the customer controls only the quality of that goods and services and the timelines Of the project. However, the quantity of the goods is left to the control of the Contractor. But in the instant case, as per the Service Work Order, they are controlling both. As per Annexure 1 they are billing the goods and labour cost separately. Hence, these are two different
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vided by the suppliers. Also there are materials supplied by the client free of cost and the rates have been worked out at actual cost of material with 15% profit on material + labour + 3% Overheads & Wastages (where M = Material component & L = Labour component). Therefore, these works orders are for supply of material and supply of labour, Hence, the said contract cannot be termed as composite supply. Q2. Whether can the applicant charge GST rate of 12% on MEP (Mechanical, Electrical, plumbing Works) activities by availing the benefit of central Tax rate notification No. 01/2018 dated 25th January, 2018, if the said supplies are in relation to an housing project enjoying infra status vide F. No. 13/6/2009-INF dated 30th March 2017 of Government of India, In Ministry of Finance, Department of Economic Affairs? Comments: The supply made by the applicant cannot be treated as composite supply as explained above in r/o Question No. 1, the applicant is not entitled to avail the exe
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on transactions effected which would be on the lines thus – We have been informed of the activities carried on by the applicant which include design, engineering, supply, installation and commissioning of plumbing, firefighting and electrical infrastructure to a wide range commercial project. Applicant in furtherance of business has entered into an agreement that is draft contract agreement with a Developer/ Builder for electrical and plumbing work. Applicant has raised question on the basis of the draft agreement and by virtue of activity of the applicant claimed as covered by the scope of Notification No. 20/2017-Central Tax (Rate) dated 22/08/ 2017 and Notification No. 1/2018 dated 25th January 2018 as amended by inserting therein in item No (V) a new subitem (da) whereby composite supply of works contract as defined in clause (119) of section 2 of GST Act, supplied by way of construction, erection, commissioning, or installation of original works pertaining to, (da) low-cost houses
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, pipes for electrical cabling work, construction of chambers in External development of________project. This has reference to your final offer dated_______regarding the External plumbing work at________ and subsequent discussion with you in presence of our Director Projects during the meeting, we herewith confirm our intention of awarding the subject matter work to your esteemed organization at the rates mentioned herein below for the specifications mentioned therein for above said works. Agreed Rate & Contract Value: – Total Value of the Contract awarded is Rs____plus GST (as applicable). Contractor shall study the detailed drawing / BOQ & site topography and revert with the final BOQ in consultation with our MEP head Mr. Prince -______, in 7 working days after receipt of LOI/ WO; we shall thereafter convert the work order on Lumsum basis. The Contract Value is arrived based on the present tax structure prevailed as on date. However, any new levy of taxes or change in present
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easonable facility to any other agency employed by the Company for carrying out of works relating to civil works, installations and other ancillary works if any, during the duration of the contract, excluding the defect liability period in the manner laid down in the said terms and conditions and shall make good any damages, etc., after the completion of such work 5. The responsibility of maintaining and security of client supplied material and assets shall lie with the Contractor. 6. Dewatering from Footing Pits or trenches will be in the scope of the Contractor. 7. Before commencing the Work, Contractor shall submit QAP (Quality assurance Plan) to the Client. 8. It is mandatory & binding upon the Contractor to fill the cubes (at least 06 Nos.) at site during every concrete pouring (for RCC Footings, Columns, Plinth Beams, Shear Walls, Slab, etc.) & shall submit the Cube Testing Reports after 7 days. 14 days & 28 days to the Client. 9. Contractor shall have strict vigilanc
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production of signed documents in original recorded jointly, by the Contractor with the authorized representative of the Client, along with proof of payments made by the Contractor during such period from time to time 13. The Shuttering design shall be prepared & submitted to the Client upon receipt of the approval from the Structural Consultant, prior to the commencement of the RCC works. 14. Contractor shall consider basic rate of Cement (OPC-53G / Vasavdatta OR equivalent) @_______F.O.R. at Site. Billing and Payment Terms:- This contract is Item Rate labour plus material contract. A contract to carry out work in respect of the scope of work defined in the said conditions in the Tender document as modified by this Work Contract to be paid for according to actual measured quantities at the rates contained in the schedule, as per Annexure-A . R.A. Bill and Final Bill:- 1. Contractor is entitled to submit his R.A. Bill on Milestone basis duly defined & mutually agreed while sig
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ion of work. Execution of Extra items/ Deviated items:- 1. The rates for deviated or extra items shall be derived from the Tender item rates as far as possible. 2. if the items of work are absolutely new, then the rate shall be worked at actual cost of materials with 15% profit on material + labour + 3 % Overheads & Wastages (where M = Material component & L = Labour component). 3. If for such extra items any material supplied by the Client free of cost than 5% on such free supply material shall be considered towards overheads and profit element. 4. The Contractor shall submit the Rate Analysis of such items along with the material bills. However, before execution of such items, prior approval in writing shall be obtained from Client in respect of rates, quantity etc. 5. In case of requirement of any items other than the scope of work of this contract to complete the work, the same shall be approved by client engineer in writing to the Contractor. Contractor shall bring the sam
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omponent then Contractor will be asked to execute the Contract accordingly with fixed pre-defined prices of required material component as finalized by the client, to be procured from client defined Contractor and with the following terms and conditions :- 1. Your contract is finalized on the basis of [(Material + 15% profit on Material) + labour + 3% Overheads & Wastages.] 2. Material component is to be derived on the basis of material indicated in item description & Other miscellaneous material required to complete work even if not indicated in item description. 3. Take of sheet of the Material, based on GFC drawing, required to complete the work in all respect, mutually agreed by both the Contractor & the Client shall be considered as the basis for arriving at Material Cost. 4. Basic rates of materials shall be indicated by client along with list of approved Contractors for 30 days payment credit. 5. Any variation in basic rate beyond a limit of (+/-) 5% due to market fl
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plete installation, Testing & Commissioning & satisfactory handing over work of Substation Electrical work, HT & LT Cabling work, DG & Cabling Work, Street Light & Cabling Works at_____ This has reference to your quotation dated______& subsequent discussion we had dated ______ we are pleased to confirm our intention Of awarding the subject matter work to you on the terms and conditions broadly depicted herein the succeeding paragraphs. 1. Contract Type:- The Contract shall be divided into two types: TYPE- I – (Material supply, Installation, testing & commissioning) This shall be purely a Item rate with Material plus Labour basis Contract for the proposed Substation electrical works, HT & LT Cabling works, DG & Cabling works, Street Light & Cabling, wherein, the Contractor shall execute an awarded Scope of Work – duly defined herein, as per the respective clauses – wherein, it is expected to carry out the complete installation so as to satisfactor
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of Work:- The Scope of Work for the Electrical Infra Works shall comprise of the following and as mentioned in attached Annexure I- Bill of Quantities :- a. Based on our mutually agreed terms, we will provide an ample storage space within the site premises. You need to ensure that the material procured & delivered at the work site under every lot shall be thus kept / properly stacked within the storage space defined & provided by the Client including an aid for its proper Lock & Key arrangement & which shall be dedicatedly controlled, operated & thoroughly secured by you & your team on day to day basis until the satisfactory completion & handing over of the awarded scope of work With due material reconciliation. Any pilferage, misplace or theft of the Client supplied material, which shall be further issued & kept under your control & custody shall be the sole responsibility of the Contractor & under such scenario, Contractor shall make amend for
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d works in Type – I Contract, for the proposed Substation electrical works, HT & LT Cabling works, DG & Cabling works, Street Light & Cabling. a. Basic rate for each item is mentioned in Annexure-Il. In case of any deviation in specification, Contractor has to seek prior written approval from Client. b. Contractor shall submit all the quotes from vendors to our Purchase dept. c. _____Purchase Dept. shall verify and approve the rate of the item. d. After the above approval Contractor shall procure and install the item at site. e. Contractor shall raise bill for the same item with basic landed approved rate (excluding GST) plus 5% for handling charges. f. It shall be mandatory for the Contractor to seek approval from the Client for each & every lot of Procurement of all the items & also for which the basic rates has been mentioned in Annexure-II. g. Any variations in the basic rates of the items will be paid or debited – as the case may be – to the Contractor accordin
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se of the following and as mentioned in attached Annexure B Bill of Quantities :- a. Based on our mutually agreed terms, we will provide & handover to you an ample storage space within the site premises. You need to ensure that the material procured & delivered at the work site under every lot shall be thus kept / properly stacked within the storage space defined & provided by the Client including an aid for its proper Lock & Key arrangement & which shall be dedicatedly controlled, operated & thoroughly secured by you & your team on day to day basis until the satisfactory completion & handing over of the awarded scope of work with due material reconciliation. Any pilferage, misplace or theft of the Client supplied material, which shall be further issued & kept under your control & custody shall be the sole responsibility of the Contractor & under such scenario, Contractor shall make amend for such losses & shall ensure that the same shall
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y GFC shop drawings to the Client. In the absence of the same, Client determined methodology and schedule of completion shall be treated as final & mandatorily binding upon the Contractor. 6. R.A. Bill and Final Bill:- a. Contractor shall have to submit two types of separate bills for respective Contract type. Cumulative amount shall be calculated for each bill for tracking purpose. b. Contractor is entitled to submit his R.A. Bill on Monthly basis based on the work progresses at the work site & at the rate not more than I bill/ month, before 10th of every month. On receipt of such R.A. Bill and after its assessment, due payment – after keeping aside retention – will be made within 15 days starting from date of receipt of certified invoice / bill at our Head Office. c. Similarly upon satisfactory completion of awarded work, Contractor shall submit Full and Final Bill duly supported by all requisite measurements, reconciliation statement for Client supplied material and Statemen
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an enclosure with each Milestone Bill as mandatory submittals. In the event if the Contractor fails to satisfy Clients / Consultants in achieving good quality of work, desired speed of work and overall timely execution of the project then the client has full rights to terminate the contract by issuing a termination notice 7 days in advance. Client also reserves the right to get part or whole work done through any other agency at Contractors sole risk and cost and Consequences. 22. General Conditions & Special Conditions of Contract (GCC &SCC) a. Coordination with Client, Architect, Consultants, Project Manager, etc.; wherever applicable shall be the integral part of Contractors Scope of Work. However the Client shall extend his full co-operation to this effect in the interest of timely completion of the project. b. The Contractor shall afford every reasonable facility to any other agency employed by the Company for carrying out of works relating to civil works, installations a
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nure of the Contract & the Contractor is not liable to claim any escalation under whatsoever circumstances. f. Points discussed & mutually agreed & duly signed by both the parties hereinafter, from time to time, during the meetings pertaining to this Work Contract & thus transformed into M.O.M.(Minutes of Meeting) shall form the part of this Contract & treated as an Addendum to this Work Order. We find that in view of above facts we have to decide whether the plumbing work undertaken by the applicant falls within the definition of supply of Works Contract. The GST Act provides definition of Composite Supply which is as below: S.2(30) of the Act, composite supply means a supply made by a taxable person to a recipient consisting, of two or more taxable supplies of goods or services or both, or any combination thereof, which are naturally bundled and supplied in conjunction with each other in the ordinary course of business, one of which is a principal supply. Illustra
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s per Section 2(119) Of the Act, works contract means a contract for building, construction, fabrication, completion, erection, installation, fitting out, improvement, modification, repair, maintenance, renovation, alteration or commissioning of any immovable property wherein transfer of property in goods (whether as goods or in some other form) is involved in the execution of such contract. We understand the expression Works Contract as is essentially a contract of service which may also involve supply of goods in the execution of the contract. It is basically a composite supply of both goods and services. In a general sense, a contract of works, may relate to both immovable and movable property. But from the perusal of above definition it can be seen that the term works contract has been restricted to contract for building, construction, fabrication, repair etc. of any immovable property only. In this view of the matter we have to decide whether the draft/proposed plumbing contract o
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ugh the relevant clauses of the draft contract we are not inclined to agree with the jurisdictional officer that there is separate supply of goods and services. We observe that all the activities to be undertaken by the applicant pursuant to agreement are integral parts of the performance of the contractual obligation by the applicant. In order to comply with the contractual obligation cast on the applicant, the applicant would be required to do various acts as per the scope of work. In our view, the acts to be committed by the applicant cannot be divided into two parts, namely supply of goods and services which are in fact inseparable. Accordingly we reject the contention of the jurisdictional officer and reiterate our stand that the plumbing contract is indivisible works contract pertaining to immovable property within the scope of section 2(119) of the GST Act. We now take up second contract comprising of compete installation testing and commissioning and satisfactory handing order
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an housing project enjoying Infra status vide F No 13/6/2009-INF dated 30th March 2017 of Government of India, in Ministry of Finance, Dept. of Economic Affairs? With respect to this question applicant was specifically informed during the course of hearing to submit document such as agreement, total area and area per dwelling etc. However, we observe that applicant has not submitted any details / evidence such as agreement entered into with a developer/ builder for the provisions Of MEP services to an affordable housing project. Therefore in the absence of detailed information in relation to housing project it is not possible for this authority to reach at definite conclusion. 06. In view of the extensive deliberations as held hereinabove, we pass an order as follows: ORDER (Under section 98 of the Central Goods and Services Tax Act, 2017 and the Maharashtra Goods and Services Tax Act, 2017) NO.GST-ARA-46/2018-19/B-119 Mumbai, dt. 28/09/2018 For reasons as discussed in the body of the
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