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An advance ruling confirmed that the development and operation of a Battery Energy Storage System (BESS) in Tamil Nadu does not qualify as electricity generation, transmission, or distribution. The BESS, which converts electrical energy into chemical energy for storage, is classified as providing support services to utilities.

As a result, the applicant is liable to pay 18% GST under HSN code 998631. The ruling clarifies that there is no sale or purchase of electricity involved, and the applicant must obtain GST registration in Tamil Nadu if the facility is established.