Authority for Advance Ruling (AAR)

1. Whether the work undertaken by the Applicant under Self-Execution Scheme through third-party contractors to shift/ re-route the transmission lines of Pashchimanchal Vidyut Vitran Nigam Limited (hereinafter referred to as “PVVNL”) can be treated as “supply” of service in terms of Section 7 of the CGST Act, 2017 between the Applicant & PVVNL? 

2. Whether there is any Assets Transfer from the Applicant to PVVNL and vice versa? 

3. Whether, at first paying GST amount on the entire value of the work done to the third-party contractors (including the cost shifting/ modification of the transmission line) and then again paying GST amount (in the name of assets transfer Charges) on the entire value of work plus supervision charges to PVVNL would result in double taxation? This is because GST is a tax on the supply of goods and services, and the same transaction should not be taxed twice. If both the contractor and PVVNL are charging GST on the same work or service, it implies that the Applicant is paying GST twice for the same transaction, which is not the intended purpose of the tax system.

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