A Tier-2 Indian cement producer operating a Rajasthan limestone-belt clinker-plus-grinding cluster procures an illustrative 3.5 million tonnes per annum of coal split between Coal India Ltd (CIL) Fuel Supply Agreement (FSA) allocations from a CIL subsidiary such as Mahanadi Coalfields Ltd or the Singareni Collieries Company Ltd, and open-market e-auction plus third-party purchases including imported coal. Every tonne carries three distinct levies stacked on top of the basic coal price — the Rs 400 per tonne Compensation Cess (post-GST manifestation of the legacy Clean Energy Cess imposed by Section 83 of the Finance Act 2010 and continued under Notification 1/2017-Compensation Cess), the GST at 5 percent on coal (HSN 2701) and the Section 194Q TDS obligation at 0.1 percent on aggregate purchases from any single seller above Rs 50 lakh in the financial year. The Section 194Q applicability was clarified by CBDT Circular 20/2021 to extend to purchases from Government-owned Public Sector Undertakings — the Government/State-Government exemption under Section 194Q(3) does not carry through to a PSU or a corporation established under a Central, State or Provincial Act. The reconciliation surface must read the CIL FSA versus e-auction split at seller-PAN level, tag every Section 194Q trigger per seller, hold the Compensation Cess register tonne-wise-seller-wise-month-wise, run the GST 5 percent ITC utilisation against Form GSTR-2B under Rule 36(4) and thread the coal landed cost into the Ind AS 2 inventory valuation and downstream into the cost of clinker and finished cement.
Build a coal-procurement register keyed on the seller PAN, tagging each invoice with the procurement route (CIL FSA / CIL e-auction / third-party domestic / third-party imported), the CIL subsidiary or coal-trader identity, the tonnage, the basic price, the Compensation Cess quantum (tonnes multiplied by Rs 400), the GST 5 percent, the inbound freight, the handling charges and any demurrage. Roll up per-seller-PAN aggregates in the financial year and trigger Section 194Q TDS at 0.1 percent on the incremental value above the Rs 50 lakh threshold — deducted on invoice basis, deposited by the seventh of the following month under Rule 30 and reported in Form 26Q at the correct payment code (Section 393 Sl. No. 8 purchase of goods under the 2026 payment code migration schedule). Maintain a Compensation Cess register alongside — tonne-wise, seller-wise, month-wise — for cost-accounting cross-reference to the monthly kiln fuel consumption record. Reconcile the GST 5 percent ITC on the coal invoices against Form GSTR-2B under Rule 36(4) each month and against Section 16(4) each September for annual claim. Thread the Ind AS 2 landed cost (basic price plus Compensation Cess plus freight plus handling plus demurrage, GST 5 percent excluded as recoverable) into raw-material inventory and downstream through the coal-consumption-per-tonne-of-clinker norm into clinker cost and through the clinker factor into finished cement cost.
Seller-PAN master with CIL-subsidiary identity flag, Government-PSU-carve-out interpretation tag (per CBDT Circular 20/2021 — PSU is not Government for Section 194Q(3)), FSA reference number and CIL price-circular reference. Coal-procurement invoice register — invoice date, seller PAN, procurement route (FSA / e-auction / third-party), coal grade (G1 to G17 for non-coking, W1 to W4 for washed, ROM for run-of-mine), tonnage, basic price per tonne, Compensation Cess (tonnes multiplied by Rs 400), GST 5 percent, inbound freight, handling charges, demurrage, landed cost per tonne. Financial-year aggregate tracker per seller PAN with Rs 50 lakh Section 194Q threshold, 0.1 percent TDS on incremental above threshold, Form 26Q filing reference and Section 393 Sl. No. 8 payment code. Compensation Cess register tonne-wise-seller-wise-month-wise for cost-accounting cross-reference. GST reconciliation surface for coal invoices against Form GSTR-2B, Rule 36(4) monthly and Section 16(4) September-cut-off flag. Ind AS 2 raw-material inventory ledger for coal with landed cost per tonne, coal-consumption-per-tonne-of-clinker norm, clinker-cost ledger and finished-cement-cost ledger. Monthly close packet template for the CFO, the plant commercial lead and the plant fuel and combustion engineering (FCE) head.
A month-end coal procurement and cost accounting packet: the coal-procurement invoice register with per-invoice traceability to seller PAN, procurement route, tonnage, price, Compensation Cess, GST and landed cost per tonne; the per-seller-PAN financial-year aggregate tracker with Section 194Q TDS position (below threshold / at threshold / above threshold with cumulative TDS deducted); the Form 26Q filing status and Section 393 Sl. No. 8 payment code reconciliation to the TDS challan; the Compensation Cess register tonne-wise-seller-wise-month-wise with cross-reference to the kiln fuel consumption record; the GST 5 percent ITC utilisation reconciliation against Form GSTR-2B with Rule 36(4) monthly variance flagged and Section 16(4) September-cut-off status; the Ind AS 2 raw-material coal inventory ledger with monthly opening balance, receipts (from procurement register), issues (to kiln), closing balance and cost per tonne; the coal-consumption-per-tonne-of-clinker KPI with variance from the plant norm flagged; the coal-cost-per-tonne-of-cement KPI reported in the plant monthly cost sheet. Multi-year continuity of the register produces the audit trail that a statutory auditor reviewing Ind AS 2 inventory valuation, a GST auditor under Section 65 reviewing input tax credit and Compensation Cess treatment, a Central Board of Direct Taxes inspector reviewing Section 194Q compliance and a cost auditor under the Companies (Cost Records and Audit) Rules 2014 reviewing the CRA-3 cost audit report all expect.
A Tier-2 Indian cement producer operating a Rajasthan limestone-belt clinker-plus-grinding cluster procures an illustrative 3.5 million tonnes per annum of coal split between Coal India Ltd (CIL) Fuel Supply Agreement (FSA) allocations from CIL subsidiaries (Mahanadi Coalfields Ltd, Central Coalfields Ltd, Singareni Collieries Company Ltd) and state-owned mineral-development corporations, and open-market e-auction plus third-party procurement including imported coal from Indonesia and South Africa. Every tonne of coal that lands at the plant boundary carries three distinct fiscal levies stacked on top of the basic coal price — the Rs 400 per tonne Compensation Cess (the post-GST manifestation of the legacy Clean Energy Cess originally imposed by Section 83 of the Finance Act 2010 and continued after 1 July 2017 under Notification No. 1/2017-Compensation Cess (Rate)), the GST at 5 percent on coal (HSN 2701 — coal; whether or not pulverised, but not agglomerated), and the Section 194Q TDS obligation at 0.1 percent on the aggregate purchase from any single seller above the Rs 50 lakh threshold in the financial year. The Section 194Q applicability to purchases from Coal India Ltd and its subsidiaries was clarified by CBDT Circular No. 20 of 2021 dated 25 November 2021 — the Government/State-Government exemption under Section 194Q(3) does not extend to a Government-owned PSU or to a corporation established under a Central, State or Provincial Act. The reconciliation discipline that reads the CIL FSA versus e-auction versus third-party split at seller-PAN level, tags every Section 194Q trigger per seller, holds the Compensation Cess register tonne-wise-seller-wise-month-wise, runs the GST 5 percent ITC utilisation against Form GSTR-2B under Rule 36(4) and threads the coal landed cost through the Ind AS 2 raw-material inventory ledger into the cost of clinker and finished cement is the subject of this coal cess Clean Energy cement plant TDS Section 194Q Wave 1 walkthrough.
Quick reference
| Aspect | Detail |
|---|---|
| Governing statute (Clean Energy Cess original imposition) | Finance Act 2010, Section 83 |
| Governing statute (Compensation Cess post-GST) | Goods and Services Tax (Compensation to States) Act 2017 |
| Compensation Cess rate on coal | Rs 400 per tonne |
| Compensation Cess notification | Notification No. 1/2017-Compensation Cess (Rate) dated 28 June 2017 (as amended) |
| Coal HSN code | 2701 |
| GST rate on coal | 5 percent |
| Section 194Q of the Income-tax Act 1961 | Introduced by the Finance Act 2021, effective 1 July 2021 |
| Section 194Q threshold | Rs 50 lakh per seller per financial year |
| Section 194Q rate | 0.1 percent on aggregate above threshold |
| Buyer turnover trigger | Rs 10 crore in preceding financial year |
| PSU carve-out clarification | CBDT Circular No. 20 of 2021 dated 25 November 2021 — Government/State exemption does not extend to a PSU or a corporation established under a Central, State or Provincial Act |
| Section 393 Sl. No. 8 payment code | Purchase of goods (Section 194Q) — payment code 6QD (illustrative pre-2026 code) / mapped payment code under the 2026 migration schedule |
| Deposit due date | Seventh of the following month (Rule 30) |
| Quarterly TDS return | Form 26Q |
| CIL subsidiaries (illustrative safe context) | Bharat Coking Coal Ltd, Central Coalfields Ltd, Eastern Coalfields Ltd, Mahanadi Coalfields Ltd, Northern Coalfields Ltd, South Eastern Coalfields Ltd, Western Coalfields Ltd, Singareni Collieries Company Ltd |
| CIL non-coking coal grades | G1 to G17 (calorific-value bands) |
| CIL washed coal grades | W1 to W4 |
| CIL run-of-mine grade | ROM |
| Illustrative FSA base price for cement plant | Rs 3,000 to Rs 3,400 per tonne (grade dependent) |
| Illustrative e-auction premium | Rs 300 to Rs 800 per tonne over FSA |
| Cement industry thermal-energy split | 40 to 45 percent from coal plus pet-coke blend |
| Ind AS 2 landed-cost inclusions | Basic coal price + Compensation Cess Rs 400/tonne + inbound freight + handling + demurrage |
| Ind AS 2 landed-cost exclusions | GST 5 percent (recoverable as ITC subject to Section 16 read-across) |
The reconciliation in one paragraph
A Tier-1 or Tier-2 Indian cement producer with a Rajasthan or Madhya Pradesh or Chhattisgarh limestone-belt clinker-plus-grinding cluster runs a multi-route coal procurement engine with three parallel fiscal reconciliation surfaces layered on top of the physical coal receipt. Surface one is the Section 194Q TDS surface — every seller PAN is a separate Rs 50 lakh threshold counter, and the aggregate crosses the threshold at different points in the financial year for the CIL FSA subsidiary, the CIL e-auction subsidiary and the third-party coal trader. Once the threshold is crossed, TDS at 0.1 percent runs on the incremental value on invoice basis, deposited by the seventh of the following month under Rule 30 and reported quarterly in Form 26Q at the Section 393 Sl. No. 8 payment code (purchase of goods). The CBDT Circular 20/2021 clarification that a Government-owned PSU is not Government for the Section 194Q(3) carve-out means CIL and its subsidiaries and Singareni Collieries Company Ltd and every state mineral-development corporation is a live Section 194Q counterparty. Surface two is the Compensation Cess register — Rs 400 per tonne on every tonne of coal received, tonne-wise, seller-wise, month-wise, flowing straight into the Ind AS 2 landed cost of coal inventory (not recoverable as ITC for a cement manufacturer because cement is not a Compensation-Cess-bearing outward supply). Surface three is the GST 5 percent ITC reconciliation — invoice-level match against Form GSTR-2B under Rule 36(4) each month and against Section 16(4) each September for the annual cut-off. All three surfaces roll up into the raw-material coal inventory ledger, cross-tie into the kiln fuel consumption record and thread through the coal-consumption-per-tonne-of-clinker norm into the finished cement cost per tonne — the KPI that the plant CFO and the cost auditor under the Companies (Cost Records and Audit) Rules 2014 both hold in the monthly close packet.
What the scenario looks like in India — a Rajasthan limestone-belt cement cluster
The illustrative persona for this walkthrough is a Tier-2 Indian cement producer operating a two-plant cluster in the Rajasthan limestone belt — a clinker plant in the Chittorgarh-Nimbahera axis (Chittorgarh district) and a grinding-plus-blending unit in the Sirohi axis (Sirohi district), a geography that also anchors the operations of Tier-1 and Tier-2 Indian cement majors including Shree Cement, JK Lakshmi Cement, Nuvoco Vistas, Birla Corporation and Prism Johnson in various combinations of clinker-and-grinding footprints. The Chittorgarh unit runs a five-stage pre-heater dry-process kiln at a clinker capacity of 3.5 million tonnes per annum (MTPA) with a specific coal consumption of approximately 720 kg of coal per tonne of clinker at the ex-kiln measurement point, translating to an annual coal requirement of 2.52 million tonnes at the clinker unit. The Sirohi grinding unit uses a smaller share of coal for the clinker-to-cement grinding energy plus in-plant utilities — the balance of the 3.5 million tonnes total annual coal procurement is split across the two units.
The 3.5 MTPA coal procurement portfolio for the cluster (illustrative — actual plant-level splits vary by CIL allocation, state coal-linkage policy and open-market conditions) breaks down as follows: 2.4 million tonnes via CIL FSA — split further between a CIL subsidiary (Central Coalfields Ltd Ranchi or Mahanadi Coalfields Ltd Sambalpur) and the Singareni Collieries Company Ltd (SCCL, a Government of Telangana and Government of India joint venture PSU); 0.7 million tonnes via CIL e-auction spot procurement; and 0.4 million tonnes via third-party procurement including imported coal from Indonesia (medium-calorific-value steam coal from Kalimantan) or South Africa (higher-calorific-value RB1/RB2 from Richards Bay) routed through a Kandla or Mundra port handling agent. The Compensation Cess of Rs 400 per tonne applies uniformly to all 3.5 million tonnes irrespective of procurement route — the annual Compensation Cess load is Rs 140 crore. The GST at 5 percent on the basic-price-plus-cess value stack — again irrespective of route — is recoverable as ITC subject to the Section 16 read-across.
Tier-1 and Tier-2 Indian cement producers operating comparable Rajasthan and Madhya Pradesh and Chhattisgarh limestone-belt clusters with multi-route coal procurement include UltraTech Cement (Aditya Birla Group — Rawan and Hirmi units in Chhattisgarh, Kotputli in Rajasthan, Kharia Khangar in Rajasthan), Shree Cement (Beawar and Ras and Khushkhera in Rajasthan), Ambuja Cements (Adani Group — Ambujanagar in Gujarat, Bhatapara in Chhattisgarh), ACC Ltd (Adani Group — Wadi in Karnataka, Kymore in Madhya Pradesh, Chanda in Maharashtra), Dalmia Bharat Cement (Ariyalur in Tamil Nadu, Kadapa in Andhra Pradesh, Bokaro in Jharkhand), JK Cement (Nimbahera and Mangrol in Rajasthan, Muddapur in Karnataka), Ramco Cements (Ariyalur in Tamil Nadu, Jayanthipuram in Andhra Pradesh), Birla Corporation (Satna in Madhya Pradesh, Chanderia and Kotputli in Rajasthan), HeidelbergCement India (Ammasandra in Karnataka, Damoh in Madhya Pradesh), JK Lakshmi Cement (Sirohi in Rajasthan, Jhajjar in Haryana), Prism Johnson (Satna in Madhya Pradesh), Nuvoco Vistas (Chittorgarh and Nimbahera in Rajasthan, Bhiwani in Haryana, Chilamkur in Andhra Pradesh), Orient Cement (Devapur in Telangana, Chittapur in Karnataka), Star Cement (Meghalaya) and India Cements (Sankarnagar in Tamil Nadu, Chilamkur in Andhra Pradesh). Each of these producers runs a coal procurement engine with variants of the same CIL FSA plus e-auction plus third-party split and lives with the same Section 194Q plus Compensation Cess plus GST 5 percent plus Ind AS 2 landed-cost reconciliation stack.
The regulatory overlay — Section 194Q, Section 83 Finance Act 2010, Compensation Cess Act 2017 and Ind AS 2
Four regulatory anchors govern a cement plant’s coal procurement fiscal close. Section 194Q of the Income-tax Act 1961 governs the buyer-side TDS on purchase of goods above the Rs 50 lakh threshold per seller. Section 83 of the Finance Act 2010 (and the subsequent GST Compensation Cess Act 2017) governs the Rs 400 per tonne cess on coal. The GST framework — Section 16 of the CGST Act 2017 and Rule 36(4) of the CGST Rules 2017 — governs the input tax credit reconciliation on the 5 percent GST component. And Ind AS 2 governs the raw-material inventory valuation and the flow of the landed cost through the cost of clinker into the cost of finished cement.
Section 194Q of the Income-tax Act 1961 was introduced by the Finance Act 2021 with effect from 1 July 2021. Section 194Q(1) requires a buyer whose total sales, gross receipts or turnover from the business carried on by him exceed Rs 10 crore during the immediately preceding financial year to deduct tax at source at 0.1 percent of the sum exceeding Rs 50 lakh on the purchase value of goods from any resident seller in that financial year. Every cement producer of any material scale in India crosses the Rs 10 crore turnover trigger, so the section is universally applicable. Section 194Q(3) provides three carve-outs — where tax is deductible under another provision, where tax is collectible under Section 206C (other than 206C(1H)), and where the buyer is notified by the Central Government subject to conditions. There was an initial industry expectation that the Government-owned status of Coal India Ltd would attract a carve-out for cement-industry coal purchases from CIL, and CBDT Circular No. 13 of 2021 dated 30 June 2021 provided initial implementation guidance without addressing the PSU question directly. CBDT Circular No. 20 of 2021 dated 25 November 2021 clarified at paragraph 3 that the Government/State-Government exemption under Section 194Q(3) does not extend to a Public Sector Undertaking or to a corporation established by or under a Central, State or Provincial Act — thereby subjecting cement-industry coal purchases from CIL and its subsidiaries (Bharat Coking Coal Ltd, Central Coalfields Ltd, Eastern Coalfields Ltd, Mahanadi Coalfields Ltd, Northern Coalfields Ltd, South Eastern Coalfields Ltd, Western Coalfields Ltd, Singareni Collieries Company Ltd) and from every state mineral-development corporation to Section 194Q TDS at the buyer end. Under the 2026 payment code migration schedule the correct Section 393 Sl. No. 8 payment code (purchase of goods) applies to the TDS deposit and Form 26Q reporting.
Section 83 of the Finance Act 2010 originally imposed the Clean Energy Cess at Rs 50 per tonne on coal, lignite and peat produced in India and on coal, lignite and peat imported into India — subsequently raised to Rs 400 per tonne by the Finance Act 2016. The Clean Energy Cess Rules 2010 governed the cess collection mechanism until 30 June 2017. Post the introduction of the Goods and Services Tax on 1 July 2017 and the subsumption of most cesses under the GST regime, the Clean Energy Cess was subsumed under the GST Compensation Cess levied on specified goods under the Goods and Services Tax (Compensation to States) Act 2017. Notification No. 1/2017-Compensation Cess (Rate) dated 28 June 2017 (as amended) specifies the Compensation Cess on coal, briquettes, ovoids and similar solid fuels manufactured from coal at Rs 400 per tonne. The Compensation Cess is payable in addition to the applicable GST rate of 5 percent on coal (HSN 2701) at the point of supply. Section 11 of the Compensation Cess Act read with Rule 3 of the Goods and Services Tax Compensation Cess Rules 2017 restricts utilisation of Compensation Cess input credit to output supply attracting Compensation Cess, and cement (HSN 2523) is not a Compensation-Cess-bearing outward supply. The Rs 400 per tonne on coal is therefore a permanent cost load for a cement manufacturer rather than a pass-through credit.
Section 16(1) of the CGST Act 2017 permits input tax credit on any supply of goods or services used in the course or furtherance of business. Section 16(2) sets four conditions — invoice possession, receipt of goods, tax actually paid to Government, and return filed. Section 16(4) restricts ITC claim to the earlier of the September return following the financial year or the annual return date. Rule 36(4) of the CGST Rules 2017 restricts ITC claim to invoices furnished by the supplier in Form GSTR-1 or through the Invoice Furnishing Facility (IFF) and communicated to the recipient in Form GSTR-2B. For a cement plant procuring 3.5 million tonnes of coal per annum with a basic-plus-cess landed value of illustrative Rs 1,260 crore, the 5 percent GST ITC of approximately Rs 63 crore per annum is a material working-capital line and the invoice-level Section 16 read-across against Form GSTR-2B is a standing month-end reconciliation. The Section 16(4) ITC exposure calculator helps model the September-cut-off exposure for the coal-invoice portfolio.
Paragraph 10 of Ind AS 2 requires the cost of inventories to comprise all costs of purchase, costs of conversion and other costs incurred in bringing the inventories to their present location and condition. Paragraph 11 elaborates that costs of purchase comprise the purchase price, import duties and other taxes (other than those subsequently recoverable by the entity from the taxing authorities), transport, handling and other costs directly attributable to the acquisition of finished goods, materials and services. For a cement plant, the Ind AS 2 landed cost of coal is the sum of the basic coal price, the Compensation Cess of Rs 400 per tonne (not recoverable as ITC — flows into the landed cost), inbound freight from the pit-head or port to the plant boundary, handling charges at the plant, and demurrage where applicable. The 5 percent GST on coal is recoverable as ITC (subject to the Section 16 conditions) and therefore excluded from the Ind AS 2 landed cost but tracked separately in the GST reconciliation surface.
A worked example — a Rajasthan cement cluster CIL FSA plus e-auction plus third-party close for FY 2026-27
Illustrative — the following figures represent the operating pattern of a Tier-2 Indian cement producer running a 3.5 MTPA Rajasthan limestone-belt cluster. Public disclosures by listed Indian cement majors do not reveal per-plant coal procurement pricing at the per-tonne, per-seller granularity below; cross-verify against your own coal procurement register, the CIL price circular in force and the CFO’s Ind AS 2 landed-cost policy before action.
The FY 2026-27 illustrative coal procurement portfolio for the cluster is 3.5 million tonnes total split across three routes and four sellers:
| Route and seller (illustrative) | Tonnage (MT) | Basic price per tonne | Basic value (Rs crore) |
|---|---|---|---|
| CIL FSA — Central Coalfields Ltd (grade G7/G8 non-coking) | 1.4 | Rs 3,150 | 44.1 |
| CIL FSA — Singareni Collieries Company Ltd (grade G6/G7 non-coking) | 1.0 | Rs 3,250 | 32.5 |
| CIL e-auction — Mahanadi Coalfields Ltd (grade G5/G6 spot) | 0.7 | Rs 3,800 | 26.6 |
| Third-party imported (Indonesia Kalimantan medium-CV) | 0.4 | Rs 5,200 | 20.8 |
| Total | 3.5 | 124.0 |
The Compensation Cess of Rs 400 per tonne applies uniformly to all 3.5 million tonnes — total Compensation Cess load of Rs 140 crore for the financial year. The GST at 5 percent applies to the basic-plus-cess value of Rs 264 crore (Rs 124 crore basic plus Rs 140 crore Compensation Cess) — total GST of Rs 13.2 crore, recoverable as ITC subject to Section 16 read-across.
Note on illustrative scaling: the basic-value column above uses simplified per-route unit prices; a working plant register carries the exact CIL price-circular rate per grade in force each month, plus mine-to-plant freight (typically Rs 400 to Rs 900 per tonne rail freight for a Rajasthan cluster on Central Coalfields Ltd or Singareni Collieries coal), plus handling and demurrage — the full landed cost per tonne varies band-wise.
The Section 194Q TDS position per seller PAN at year-end is:
| Seller PAN (illustrative) | FY 2026-27 aggregate purchase | Amount above Rs 50 lakh threshold | Section 194Q TDS at 0.1% |
|---|---|---|---|
| Central Coalfields Ltd (CIL subsidiary) | Rs 44.10 crore | Rs 43.60 crore | Rs 4,36,000 |
| Singareni Collieries Company Ltd | Rs 32.50 crore | Rs 32.00 crore | Rs 3,20,000 |
| Mahanadi Coalfields Ltd (CIL subsidiary) | Rs 26.60 crore | Rs 26.10 crore | Rs 2,61,000 |
| Third-party imported coal trader (single seller aggregate) | Rs 20.80 crore | Rs 20.30 crore | Rs 2,03,000 |
| Total Section 194Q TDS deducted for FY 2026-27 | Rs 12,20,000 |
Each seller’s aggregate crosses the Rs 50 lakh threshold at a different point in the financial year — typically the CCL and SCCL FSA aggregates cross by end of April, the MCL e-auction aggregate crosses by end of June, and the imported-coal aggregate crosses by end of August. TDS at 0.1 percent runs on the incremental value on invoice basis from the crossing invoice onwards, deposited by the seventh of the following month under Rule 30 and reported quarterly in Form 26Q at the Section 393 Sl. No. 8 payment code (purchase of goods). The Section 393 payment code finder tool helps map the exact 2026-migration payment code for each TDS deposit.
The Compensation Cess register for the year is tonne-wise-seller-wise-month-wise — an illustrative row for June 2026 might read: CCL FSA 130,000 tonnes at Rs 400 = Rs 5.2 crore; SCCL FSA 85,000 tonnes at Rs 400 = Rs 3.4 crore; MCL e-auction 55,000 tonnes at Rs 400 = Rs 2.2 crore; imported coal 33,000 tonnes at Rs 400 = Rs 1.32 crore; June total Rs 12.12 crore. The monthly Compensation Cess load cross-ties to the kiln fuel consumption record from the plant Distributed Control System (DCS) or Programmable Logic Controller (PLC) log — any variance between coal-inventory-issued-to-kiln and kiln-fuel-consumption-recorded flags either a stock-taking discrepancy or a metering-calibration drift for investigation.
The Ind AS 2 landed cost per tonne of coal for the June 2026 receipts, illustrative, works out approximately as follows for the largest-volume CCL FSA route: basic price Rs 3,150 + Compensation Cess Rs 400 + inbound rail freight from Ranchi region to Chittorgarh Rs 750 (illustrative) + plant handling Rs 40 + demurrage Rs 15 = landed cost Rs 4,355 per tonne. The 5 percent GST of Rs 158 per tonne (on Rs 3,150 basic + Rs 400 Compensation Cess = Rs 3,550 GST-taxable base multiplied by 5 percent) is excluded from the Ind AS 2 landed cost — captured separately in the GST ITC surface for Form GSTR-2B reconciliation. The landed cost of Rs 4,355 per tonne flows into the raw-material coal inventory ledger and, via the specific coal consumption norm of approximately 720 kg per tonne of clinker for a five-stage pre-heater dry-process kiln, into the cost of clinker at approximately Rs 3,136 per tonne of clinker (0.720 tonne of coal at Rs 4,355 = Rs 3,136). The clinker cost then flows into the finished cement cost via the clinker factor — for a Portland Pozzolana Cement (PPC) product with a 30 percent fly ash blend under IS 1489, the clinker factor is approximately 65 percent (65 percent clinker + 30 percent fly ash + 5 percent gypsum) and the clinker contribution to the cement cost is Rs 2,038 per tonne of cement.
Common reconciliation breakages
Five breakages recur across Indian cement producers running the multi-route CIL FSA plus e-auction plus third-party coal procurement with Section 194Q plus Compensation Cess plus GST 5 percent ITC plus Ind AS 2 landed-cost close.
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Section 194Q aggregation at the wrong PAN level. Section 194Q applies to the aggregate purchase from a single seller in the financial year above the Rs 50 lakh threshold — and a cement plant procuring from multiple CIL subsidiaries (Central Coalfields Ltd, Mahanadi Coalfields Ltd, Bharat Coking Coal Ltd, Singareni Collieries Company Ltd) must aggregate at the PAN level of each subsidiary separately. Rolling all CIL purchases into a single “CIL group” aggregate triggers TDS deduction sooner than the correct per-PAN aggregation and over-deducts TDS; rolling only some purchases (e.g. treating SCCL as a separate group but grouping the three CIL subsidiaries together) triggers under-deduction on the crossed-but-not-recognised aggregates. Reconciliation discipline: the coal-procurement register is keyed on the seller PAN, the financial-year aggregate is rolled at the seller-PAN level and the Section 194Q trigger point is recognised per PAN with a documented aggregation policy note in the CFO close packet. Terra Insight’s reconciliation failure mode analysis for India design pillar and reconciliation playbook for monthly close operations pillar frame the design-and-operate discipline that surfaces the PAN-aggregation failure at the crossing invoice rather than at the year-end tax audit.
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PSU carve-out misinterpretation — legacy exempt-tagging of CIL FSA purchases. Pre CBDT Circular 20/2021 (November 2021), industry confusion on whether CIL’s Government-owned status attracted the Section 194Q(3) exemption led some plants to tag FSA purchases as Section 194Q-exempt. The correct post-Circular 20/2021 position is that PSU is not “Government” for Section 194Q(3) — CIL, its subsidiaries and Singareni Collieries Company Ltd are all subject to Section 194Q at the buyer end. Any legacy exempt-tagging on FY 2021-22 or FY 2022-23 CIL FSA purchases must be re-audited and reversed with catch-up TDS deposit plus interest under Section 201(1A) at 1 percent per month from the date TDS ought to have been deducted to the date of actual deduction, and 1.5 percent per month from the date of actual deduction to the date of deposit. Reconciliation discipline: an annual Section 194Q counterparty-status review confirms the PSU carve-out interpretation against the current CBDT circular position, and any exempt-tag on a CIL-subsidiary or state-mineral-corporation PAN is flagged for CFO re-approval each year.
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Compensation Cess register drift — cess captured at aggregate level instead of invoice level. The Rs 400 per tonne Compensation Cess must be captured on invoice basis into the Ind AS 2 landed cost — tonne-wise, seller-wise, month-wise, with cross-reference to the specific coal grade and CIL price-circular reference. A plant that captures the cess only at monthly aggregate level (say Rs 12 crore in June without the per-invoice split) loses the per-invoice traceability that a statutory auditor reviewing Ind AS 2 inventory valuation or a GST audit under Section 65 will demand. The aggregate-level capture also masks any per-invoice cess-rate discrepancy — for example, a supplier who charges Compensation Cess at Rs 400 per tonne on a stock-transfer between two CIL subsidiaries (typically a nil-cess transaction under intra-CIL branch transfer rules) or who mis-quotes the cess on an amended-invoice recalculation. Reconciliation discipline: the coal-procurement register carries a dedicated Compensation Cess column at the invoice-line level, and the monthly aggregate is a computed roll-up rather than a hand-entered figure.
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GST 5 percent ITC Section 16(4) breach on delayed matching. The ITC on coal GST must be claimed by the earlier of the September return following the financial year or the annual return date under Section 16(4). Rule 36(4) further restricts the claim to invoices furnished by the supplier in Form GSTR-1/IFF and communicated to the recipient in Form GSTR-2B. A plant that fails to reconcile the coal-supplier invoices against Form GSTR-2B within the monthly cycle risks two-way exposure: an invoice not appearing in GSTR-2B by the monthly cycle is not eligible for ITC in that month under Rule 36(4); an invoice not appearing in GSTR-2B by the September cut-off breaches Section 16(4) and the ITC is permanently lost. For a cement plant with Rs 63 crore of annual coal GST ITC across four to six supplier PANs, even a small percentage of unmatched invoices carrying into the September cut-off can produce a several-crore rupee ITC leakage. Reconciliation discipline: the coal-invoice ITC surface runs a two-way match (procurement register versus Form GSTR-2B) each month with supplier-follow-up on any unmatched invoice, and the September pre-cut-off packet flags any residual unmatched value for supplier escalation or ITC reversal decision.
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Coal-consumption-per-tonne-of-clinker KPI drift not tied to procurement register. The specific coal consumption norm for a well-run five-stage pre-heater dry-process kiln is approximately 700 to 780 kg of coal per tonne of clinker at the ex-kiln measurement point (varies by kiln design, coal calorific value, pre-heater efficiency and downtime pattern). A plant that reports coal-consumption-per-tonne-of-clinker as a plant-metric-in-isolation without tying it back to the coal-procurement register and the kiln-fuel-consumption record from the DCS/PLC log misses the operational cross-tie that surfaces a metering drift, a stock-taking discrepancy or a coal-grade slippage (a lower-calorific-value G-grade coal requiring more tonnes to deliver the same kiln-heat-input). Reconciliation discipline: the monthly cost sheet ties the coal-inventory-issued-to-kiln (from the raw-material inventory ledger) to the coal-consumption-recorded-at-kiln (from the DCS log) to the clinker-produced (from the ex-kiln clinker-hopper metering), with any variance greater than 1.5 percent flagged for the plant fuel and combustion engineering (FCE) head. The Terra Insight human errors detection envelope anchor frames the seven-family human-error taxonomy that surfaces the metering-to-ledger reconciliation gap and its coverage limits honestly.
How a reconciliation platform handles this
A purpose-built cement reconciliation platform ingests every CIL FSA invoice, e-auction lot invoice and third-party coal invoice against a coal-procurement register keyed on the seller PAN, tags each invoice at capture with the procurement route (FSA / e-auction / third-party domestic / third-party imported), the CIL subsidiary or coal-trader identity, the coal grade (G1 to G17 for non-coking, W1 to W4 for washed, ROM for run-of-mine), the tonnage, the basic price, the Rs 400 per tonne Compensation Cess, the GST 5 percent and the landed-cost build-up including inbound freight and handling and demurrage. The platform rolls the financial-year aggregate at the seller-PAN level, triggers Section 194Q TDS at 0.1 percent on the incremental value above the Rs 50 lakh threshold, confirms the deposit by the seventh of the following month under Rule 30 and reports quarterly in Form 26Q at the Section 393 Sl. No. 8 payment code. The Compensation Cess register runs tonne-wise-seller-wise-month-wise with cross-reference to the kiln fuel consumption record; the GST 5 percent ITC surface runs an invoice-level two-way match against Form GSTR-2B under Rule 36(4) each month and against Section 16(4) each September; the Ind AS 2 raw-material coal inventory ledger runs the landed cost per tonne through the coal-consumption-per-tonne-of-clinker norm into the clinker-cost ledger and through the clinker factor into the finished-cement-cost ledger. Match-rate improvement of 51 to 88 percent on the coal-procurement-register-to-invoice-portfolio reconciliation, combined with an ISO 27001:2022 security posture and DPDP Act 2023 aligned data handling for CBDT-facing and GST-audit-facing submissions, is what makes the platform an infrastructure investment for a Tier-1 or Tier-2 Indian cement producer running a multi-plant multi-route coal procurement engine — rather than a spreadsheet substitute that leaves the per-seller-PAN aggregation, the CBDT Circular 20/2021 PSU-carve-out interpretation, the tonne-wise Compensation Cess register discipline and the September-cut-off ITC reconciliation as manual overheads on a hybrid plant-commercial-plus-finance-plus-tax team. The commercial pillar for the cement sub-cluster is cement reconciliation software India; the broader authority for the platform is reconciliation software India. The cross-cluster Chapter 27 IDS refund bar Notification 9/2022 chemicals walkthrough and the chemical inverted duty refund Chapter 27 blockage calculator frame the sibling Chapter 27 mechanic on the pet-coke side of the same fuel-blend portfolio; the sibling pet-coke import IGST cement plant Chapter 27 Notification 9/2022 reconciliation covers the cement-side pet-coke IDS blockage; and the Section 194Q TDS chemical purchase 50 lakh buyer-side reconciliation walkthrough covers the parallel chemicals-cluster Section 194Q mechanic.
- ▸ Section 194Q of the Income-tax Act 1961 — Introduced by the Finance Act 2021 with effect from 1 July 2021. Section 194Q(1) requires a buyer whose total sales, gross receipts or turnover from the business carried on by him exceed Rs 10 crore during the immediately preceding financial year to deduct tax at source at the rate of 0.1 percent of the sum exceeding Rs 50 lakh on the purchase value of goods from any resident seller in that financial year. Section 194Q(3) provides that the section shall not apply to a transaction on which tax is deductible under any other provision of the Act, tax is collectible under Section 206C (other than Section 206C(1H)), or the buyer is a person as may be notified by the Central Government subject to conditions. Section 194Q(5) clarifies that the Central Government may issue notifications to remove difficulties in giving effect to the section, and CBDT Circular 20/2021 dated 25 November 2021 clarifies (paragraph 3) that the Government/State-Government exemption does not extend to a Public Sector Undertaking or a corporation established by or under a Central, State or Provincial Act — thereby subjecting purchases from Coal India Ltd (CIL) and its subsidiaries (Bharat Coking Coal Ltd, Central Coalfields Ltd, Eastern Coalfields Ltd, Mahanadi Coalfields Ltd, Northern Coalfields Ltd, South Eastern Coalfields Ltd, Western Coalfields Ltd, Singareni Collieries Company Ltd) to Section 194Q TDS at the buyer end.
- ▸ Finance Act 2010, Section 83 — Clean Energy Cess — Section 83 of the Finance Act 2010 imposed a Clean Energy Cess at a rate not exceeding Rs 50 per tonne (initially, subsequently raised to Rs 400 per tonne by the Finance Act 2016) on coal, lignite and peat produced in India and on coal, lignite and peat imported into India. The Clean Energy Cess Rules 2010 governed the cess collection mechanism. The Clean Energy Cess was designed to finance and promote clean-energy initiatives and research and development in the National Clean Environment Fund (NCEF). Post the introduction of the Goods and Services Tax on 1 July 2017 and the subsumption of most cesses under the GST regime, the Clean Energy Cess was subsumed under the GST Compensation Cess levied on specified goods (including coal at Rs 400 per tonne) under the Goods and Services Tax (Compensation to States) Act 2017. The continuing Rs 400 per tonne cess on coal — whether captured as Clean Energy Cess on legacy stock or as Compensation Cess on post-GST supply — is a material line item for a cement plant consuming 40 to 45 percent of its thermal energy from coal and pet-coke blend.
- ▸ Goods and Services Tax (Compensation to States) Act 2017 and Rate Notification — The Goods and Services Tax (Compensation to States) Act 2017 provides for the levy of Compensation Cess on specified supplies of goods and services to compensate the States for the loss of revenue arising on account of implementation of the Goods and Services Tax. Notification No. 1/2017-Compensation Cess (Rate) dated 28 June 2017 (as amended) specifies the rate of Compensation Cess on coal, briquettes, ovoids and similar solid fuels manufactured from coal at Rs 400 per tonne. This Rs 400 per tonne cess is the operative post-GST manifestation of the legacy Clean Energy Cess and is payable in addition to the applicable GST rate of 5 percent on coal (HSN 2701 — coal; whether or not pulverised, but not agglomerated). The Compensation Cess is collected at the point of supply and is available as input tax credit only for outward supply of goods and services attracting Compensation Cess (which for a cement manufacturer is a nil position — cement is not a Compensation-Cess-bearing outward supply). The Rs 400 per tonne on coal is therefore a permanent cost load rather than a pass-through credit for a cement plant.
- ▸ Central Goods and Services Tax Act 2017, Section 16 and Rule 36(4) — Section 16(1) of the CGST Act 2017 permits a registered person to take input tax credit on any supply of goods or services or both used or intended to be used in the course or furtherance of business. Section 16(2) sets four conditions — (a) possession of tax invoice or debit note, (b) receipt of the goods or services, (c) tax charged has been actually paid to the Government, and (d) the return has been filed. Section 16(4) restricts input tax credit claim to the earlier of the due date for furnishing the return under Section 39 for the month of September following the end of the financial year to which such invoice or debit note pertains or furnishing of the relevant annual return. Rule 36(4) of the CGST Rules 2017 restricts input tax credit claim to only those invoices that have been furnished by the supplier in Form GSTR-1 or through the Invoice Furnishing Facility (IFF) and communicated to the recipient in Form GSTR-2B. For a cement plant procuring 3.5 million tonnes of coal per annum, the ITC on the 5 percent GST component of the coal landed cost (illustrative Rs 55 crore per annum on Rs 1,120 crore of pre-GST coal cost) is a material working-capital line and the invoice-level Section 16 read-across is a standing month-end reconciliation.
- ▸ Ind AS 2 Inventories (Companies (Indian Accounting Standards) Rules 2015) — Ind AS 2 prescribes the accounting treatment for inventories including the cost formulas and the determination of net realisable value. Paragraph 10 provides that the cost of inventories shall comprise all costs of purchase, costs of conversion and other costs incurred in bringing the inventories to their present location and condition. Paragraph 11 elaborates that costs of purchase comprise the purchase price, import duties and other taxes (other than those subsequently recoverable by the entity from the taxing authorities), transport, handling and other costs directly attributable to the acquisition of finished goods, materials and services — trade discounts, rebates and other similar items are deducted in determining the costs of purchase. For a cement plant procuring coal under CIL Fuel Supply Agreement plus e-auction plus third-party routes, the Ind AS 2 landed cost of coal includes the basic coal price, the Compensation Cess of Rs 400 per tonne (not recoverable as ITC for a cement manufacturer), inbound freight from the pit-head or port to the plant boundary, handling charges at the plant, and demurrage where applicable — all summed into the raw-material inventory bucket for finished-goods clinker and cement conversion accounting. The 5 percent GST on coal is recoverable as ITC (subject to Section 16 conditions) and therefore excluded from the Ind AS 2 landed cost, but must be tracked separately in the GST reconciliation surface.