The petitioner association sought directions for clarification on GST applicability to Battery Energy Storage Systems (BESS), contending that ambiguity had arisen due to tender conditions issued by SECI. The factual background showed that the tender required GST to be passed through, creating uncertainty on ITC eligibility and tax incidence.

The Court held that SECI has no authority to issue binding clarifications determining GST liability. Clarification on taxability falls within the domain of statutory authorities under the GST law. Directions were issued for appropriate consideration by competent authorities, while reiterating that SECI’s tender conditions cannot override statutory provisions.