No lower GST rate for general electrical supplies to ISRO space centre
Supply of general electrical equipment to research institutions like SDSC-SHAR does not qualify for concessional GST rates under Notification 45/2017.
- Ruling
- AAR/AP/05(GST)/2018 dated 10.05.2018
- Dated
- 10 May 2018
- Authority
- Authority for Advance Ruling
This page was written by Patron Accounting’s AI from the official release and reviewed before publishing. It explains the document in plain language. It is not the document itself. Where this page and the original differ, the original governs.
The short version
- M/s C R Enterprises asked if general electrical supplies get lower GST rates.
- AP AAR ruled that concessional GST rates do not apply to these items.
- The recipient Satish Dhawan Space Centre is a recognised research institution.
- Lower GST applies only to specific scientific equipment not standard electrical goods.
In short
M/s C R Enterprises asked the Andhra Pradesh Authority for Advance Ruling in order AAR/AP/05(GST)/2018 whether supplying electrical panels, transformers, and cables to Satish Dhawan Space Centre qualifies for a reduced Goods and Services Tax (GST) rate. The company believed Notification No. 45/2017-Central Tax (Rate) allowed a lower tax rate for supplies made to government research institutes.
What has changed
How it worked before
Before this ruling, many suppliers assumed that selling any goods or works to a government-funded research institute automatically allowed them to charge a lower GST rate.
What has changed
The authority ruled that getting a lower GST rate requires meeting two separate conditions: the buyer must be an eligible research institute, and the items supplied must be scientific or technical apparatus. Standard electrical equipment, transformers, wiring, and installation works are general infrastructure items. Therefore, full regular GST rates apply to these goods.
Who this affects
Contractors, electrical component suppliers, and service providers selling power equipment or installation services to research institutes and space research facilities.
An example
Apex Power Solutions supplies high-voltage wiring and distribution panels to a national space research laboratory. The laboratory gives them a certificate asking for a concessional GST rate under Notification No. 45/2017-Central Tax (Rate). Based on the logic in this ruling, Apex Power Solutions should charge the regular GST rate because general power wiring is not a scientific instrument. If they charge the lower rate, they risk having to pay the shortfall later.
What you should do
Vendors should review both the buyer's status and the exact description of goods before applying reduced GST rates. Keep in mind that an advance ruling binds only the business that applied for it and its tax office. Other businesses must evaluate their specific supply contracts or apply for their own advance ruling.
If you do nothing
If you incorrectly charge a lower GST rate on regular items sold to a research institute, the tax department will treat it as short payment of tax. The tax officer will issue a demand to recover the unpaid GST along with interest and penalties. Relying on someone else's advance ruling will not protect your business during a tax audit.
The terms explained
- advance ruling
- A formal decision by tax authorities giving a specific business clarity on how GST laws apply to its proposed or existing transactions.
- concessional rate
- A reduced tax rate permitted by the government for specified goods, services, or eligible buyers.
- public funded research institution
- A scientific or academic research organization established or funded primarily by government funds.
The ruling in detail
Authority for Advance Ruling
M/s C R ENTERPRISES
AAR/AP/05(GST)/2018 dated 10.05.2018 · Andhra Pradesh
Questions before the authority
- Whether the supplies made to SRI HARI KOTA HIGH ALTITUDE RANGE (SHAR), / SATISH DHAWAN SPACE CENTRE, located at Sri Hari Kota, Andhra Pradesh, are eligible for concessional rate of tax as per the notifications 45/2017 (Central Tax - Rate), dated 14th November 2017, and 47/2017 (Integrated Tax-Rate), dated 14th November 2017.
Facts
The applicant supplies electrical items, power distribution panels, transformers, cables, lighting fixtures, and maintenance/installation works to Satish Dhawan Space Centre (SDSC - SHAR). SDSC (SHAR) is a public-funded research institution under the administrative control of the Department of Space, Government of India. The applicant sought an advance ruling to determine if its supplies qualify for concessional GST rates under Notification No. 45/2017-Central Tax (Rate) and Notification No. 47/2017-Integrated Tax (Rate).
Ruling
| Question | What the authority ruled |
|---|---|
| Applicability of concessional rate under Notification No. 45/2017-CT(R) and 47/2017-IT(R) for electrical and maintenance supplies to SDSC (SHAR) | Not applicable Supplied goods do not fall within the specified categories in Column 3 of the Notification table |
The Authority held that the **concessional rate of GST is not applicable** to the applicant's supplies to SDSC (SHAR). Although SDSC (SHAR) is an eligible public-funded research institution, the general electrical equipment, panels, installation works, and power distribution systems supplied do not fall within the specified categories of scientific or technical instruments enumerated in the notification.
Reasoning
Notification No. 45/2017-Central Tax (Rate) grants a concessional tax rate strictly to specified items supplied to public-funded research institutions. Column 3 of the notification explicitly restricts eligible goods to scientific and technical instruments/apparatus, accessories/consumables, computer software, and prototypes. General electrical accessories, transformers, panels, wiring, motors, and maintenance works do not meet these specific criteria. Consequently, despite the recipient being a qualified institution, the **nature of the supplied goods disentitles** the transaction from the benefit of the concessional rate.
Provisions relied on
- Notification No. 45/2017-Central Tax (Rate) dated 14.11.2017
- Notification No. 47/2017-Integrated Tax (Rate) dated 14.11.2017
- Section 98(1) of CGST Act, 2017
- Section 100 of APGST Act, 2017
For the practitioner
This ruling establishes that claiming a concessional GST rate under Notification No. 45/2017-CT(R) requires **dual compliance**: the recipient must be an eligible research institution and the goods must strictly fall within the specified categories of scientific/technical apparatus or software. General electrical, civil, or power infrastructure supplies **do not qualify** for the concession.
Source
This is a summary prepared from the published order, which is a scanned document. It is a reading aid and not the authority: where the two differ, the order governs. Verify every provision against the original before relying on it.
Original order: https://www.gstcouncil.gov.in/sites/default/files/AAR/ap_05-2018_10-05-18_cr_enterprises.pdf
Legibility of the scan, as read: high.
Prepared 17-10-2026.
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