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Control CheckArticle·8 March 2026

Checklist for GST Governance of a Power Co

By J the App

Executive Summary

The electricity sector operates within a structurally complex GST framework where electricity itself remains outside GST while most inputs, services, and capital goods used in generation attract GST. This structural mismatch often results in significant input tax credit blockages and increased project costs. Power companies also operate within complex commercial arrangements involving EPC contracts, renewable energy procurement, captive consumption models, power purchase agreements, infrastructure transfers, and multi-location corporate operations. These arrangements create GST exposure in areas such as ITC reversals, EPC contract classification disputes, valuation of free issue materials, infrastructure transfer taxation, related-party service valuation, and vendor compliance risks. This control checklist is designed as a GST governance framework for power sector companies, establishing structured checkpoints across tax interpretation governance, project structuring, procurement tax planning, infrastructure development, operational compliance, and internal audit mechanisms. Implementation of these controls enables organisations to strengthen audit defensibility, detect compliance risks early, and optimise tax-efficient project structuring.

Power generation projects involve large capital investments, long construction cycles, complex engineering contracts, and regulatory oversight under the electricity regulat...

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