7.4 The appellant submitted that GAAR, despite holding that appellant'sproduct fulfill both the mandatory conditions that theproduct/ goods supplicd to Solar Power Project are falling within notified/ admissible ITC(l-ls) Code 85 and the saidgoods arc essential and integral parts of the Solar Power Generating System, did notgive any ruling, observing one irrelevant general clause of purchase order and claiming that there is possibility or likelihood of service also beingprovided by appellant to the buyer/project authority, rvhich is unjustified and baseless. The appellant submitted that in every sale/purchase contract, multiple elements of scrvices are involved at the sellers/suppliers end which includes as mentioned inpurchase order i.e. "Design, Engineering, manufacturing, assembly, inspection and testing at works, supply. packing and forwarding, transportation and transit insurancc" rvhich are essential to meet customer's specifications and also arrange delivery either at ex-factory gate basis or for destination basis. The appellant had not provided any aftcr sale scrvicc viz. no crcction, installation, construction etc. in respect of solar powcr gcnerating system and therefore, the above referred services are inbuilt and naturally bundled with principal supply ol goods and not provided beyond the sale ofgoods and hence cannot be treated separately.
