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How-To · 12 min read

Swappable Battery-as-a-Service (BaaS) Reconciliation for Indian EV OEMs

Swappable BaaS — pioneered in India by Sun Mobility, Lithion Power and Battery Smart — separates battery ownership from vehicle ownership and creates one of the most architecturally complex reconciliation problems in EV financial operations: per-swap pricing tied to battery health, Ind AS 36 impairment cycle on a depreciating fleet of 4,200+ batteries, dual GST treatment of monthly subscription (continuous supply) versus per-swap fee (point-in-time supply), site-host commission and aggregator settlement layered on top.

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Published 12 June 2026
Domain expertise
TDS Reconciliation GST Input Credit Platform Settlements NACH Batch Matching Bank Reconciliation Form 26AS Matching ERP Integrations Enterprise Finance Ops
Knowledge Card
Problem

An Indian swappable-BaaS operator with a 4,200-battery fleet across 580 swap stations confronts a dual-rail reconciliation problem: an asset ledger of per-battery Ind AS 36 CGUs with monthly capacity-fade impairment testing, and a revenue ledger of multi-component supplies (monthly subscription, per-swap fee, end-of-life battery resale) each with its own Ind AS 115 recognition pattern and GST classification. Layered on are Section 393 codes 1007/1009/1010 TDS to site hosts and aggregators, Section 394 code 1023 TCS on scrap battery sales, and a battery-circulation ledger that must tie each swap event to a specific battery serial number for audit traceability.

How It's Resolved

Maintain a battery-asset master keyed by serial number with manufacturing date, chemistry, kWh nameplate, cumulative cycles, depth-of-discharge profile, current capacity-fade percentage, location (station-of-residence at any time), Ind AS 36 carrying value and impairment-flag status. Run a per-swap event ledger linking rider, station, batteries-in and batteries-out, swap-fee charged and BMS telemetry snapshot. Recognise monthly subscription over period and per-swap fee at event under Ind AS 115. Run quarterly impairment testing on the battery fleet with indicators trigger from BMS capacity-fade beyond threshold. Tie site-host accruals at agreed rental or commission rate; deduct Section 393 codes 1007/1009/1010 TDS at outbound payment; reconcile aggregator settlement files weekly; classify end-of-life battery resale at HSN 8507 (used) or 8548 (scrap) with Section 394 code 1023 TCS at 1 percent on scrap.

Configuration

Battery-asset master with per-serial CGU tracking, BMS telemetry feed, cumulative cycles, capacity-fade, Ind AS 36 impairment status; swap-station master with site-host structure (rental / commission), CESL flag where applicable; rider master with subscription tier, GSTIN where corporate, and aggregator-of-origin where applicable; swap-event ledger with battery-in serial, battery-out serial, fee charged and GST output; site-host master with Section 393 code (1007 or 1009); aggregator master with Section 393 code 1010 and Section 52 CGST TCS flag; end-of-life-battery disposal register with HSN classification and Section 394 code 1023 TCS log.

Output

A per-battery monthly asset-status report with cumulative cycles, capacity fade, Ind AS 36 carrying value and impairment flag; a per-swap-event ledger with rider, station, batteries-in/out and fee; monthly subscription revenue recognised over period plus per-swap fee at event with 18 percent GST output; site-host rental and commission accruals with Section 393 codes 1007/1009 TDS deducted; aggregator settlement reconciliation with Section 393 code 1010 TDS and Section 52 CGST TCS credit; end-of-life battery disposal register with Section 394 code 1023 TCS on scrap sales; quarterly Form 26AS chase by counterparty TAN.

A swappable-BaaS operator running 4,200 batteries across 580 swap stations in Bengaluru, Hyderabad, Chennai, Delhi-NCR, Mumbai and Pune closes May 2026 with 12.4 lakh swap events, ₹8.6 Cr of swap revenue, ₹3.2 Cr of monthly-subscription revenue, 18 batteries impaired below the Ind AS 36 recoverable threshold and 42 batteries sold for scrap recycling. The CFO walks four reconciliation rails concurrently: an Ind AS 36 asset ledger of per-battery CGUs, an Ind AS 115 revenue ledger with two recognition patterns, a GST classification across subscription / swap / resale / scrap, and a Section 393 TDS chase across site hosts, aggregators and (on the receivables side) corporate fleet customers who deduct code 1002 on the gross invoice. Swappable battery BaaS reconciliation India is fundamentally dual-rail — asset side and revenue side — and the discipline required to close both cleanly is what separates a BaaS operator with audit-grade controls from one carrying unrecognised impairment and stale TDS receivables.

Quick reference

ItemValueSource
SubscriptionContinuous supply, SAC 998599 18%Section 13 CGST + Circular 177/09/2022
Per-swap feePoint-in-time supply, SAC 998599 18%Section 12 CGST
End-of-life battery resaleHSN 8507 at 18%CGST tariff
Scrap battery resaleHSN 8548 + Section 394 code 1023 TCS at 1%Rule 55
Ind AS 36 impairmentPer-battery CGU, annual + indicator-triggeredInd AS 36
Site-host rentalSection 393 code 1009 — 10%Legacy 194I
Site-host commissionSection 393 code 1007 — 2%Legacy 194H
Aggregator platform feeSection 393 code 1010 — 1%Legacy 194O
Aggregator Section 52 CGST TCS0.5% CGST + 0.5% SGST (or 1% IGST)CGST Section 52
Corporate-fleet receivableSection 393 code 1002 — 1-2%Legacy 194C

What does the BaaS commercial model actually look like?

The core innovation: separate battery ownership from vehicle ownership. The rider buys the vehicle without a battery at a 30-40 percent lower upfront price. The battery is owned by the BaaS operator who runs a network of swap stations. When the rider’s battery is depleted, the rider visits a swap station, places the battery in a slot, and receives a charged battery in 60-90 seconds. The rider pays a monthly subscription plus a per-swap fee (with the subscription typically including a bundle of swaps).

The dominant Indian operators:

OperatorNetwork footprintOEM relationships
Sun MobilityMulti-city pan-India networkPiaggio Ape Electric, Bajaj RE, multiple 2W partners
Lithion PowerUrban delivery focusZomato fleet, Swiggy fleet, Rapido pilot
Battery SmartLargest by station count, 35+ citiesMultiple OEM-agnostic vehicle types
HPCL / IOC pilotPetrol-pump-network deploymentPilot programmes with multiple OEMs

The commercial pattern is overwhelmingly gig-economy delivery riders (Zomato, Swiggy, Rapido, Porter, Dunzo) and urban delivery-fleet operators where battery utilisation is high and the upfront-cost reduction is decisive.

What are the four reconciliation rails?

Rail 1 — Per-battery Ind AS 36 impairment

Each battery is a separately tagged cash-generating unit (CGU) with:

  • Manufacturing date and chemistry (NMC / LFP)
  • kWh nameplate
  • Cumulative swap cycles (one cycle equals one full discharge-charge round)
  • Depth-of-discharge profile from BMS telemetry
  • Current capacity fade (percent of original capacity remaining)
  • Internal resistance from BMS
  • Useful-life assumption (typically 4-7 years from manufacturing)
  • Recoverable amount (higher of fair-value-less-costs-to-sell and value-in-use)
  • Carrying value on the balance sheet
  • Impairment-flag status

Ind AS 36 requires impairment testing whenever indicators are present. For a BaaS battery fleet the standard indicators are:

  • Capacity fade beyond a threshold (typically 75-80 percent of original nameplate)
  • Internal resistance beyond a threshold
  • Anomalous BMS thermal events
  • End-of-useful-life approach

A 4,200-battery fleet will typically run 0.4-0.8 percent monthly impairment incidence — 18-34 batteries per month requiring write-down to recoverable amount. The reconciliation tracks per-battery carrying value at month-end and runs the impairment computation against the year-end audit.

Rail 2 — Subscription and per-swap revenue recognition

Two Ind AS 115 patterns concurrently:

  • Subscription — continuous supply over the subscription period (monthly). Revenue recognised straight-line over the month. GST output at 18 percent SAC 998599 at month-start invoicing.
  • Per-swap fee — point-in-time supply at swap event. Revenue recognised at swap completion. GST output at 18 percent SAC 998599 at swap-event invoicing (typically aggregated daily or weekly to reduce invoice count).

A typical commercial structure: ₹999 per month for 20 swaps included, ₹35 per additional swap. The rider’s monthly bill is the fixed ₹999 plus the variable per-swap component above 20.

Rail 3 — Site-host and aggregator payments

Swap stations sit at third-party locations:

  • Petrol pumps (HPCL, IOC, BPCL forecourt corners)
  • Kirana stores (Zepto / Blinkit / Instamart dark-store partners and standalone)
  • Delivery-aggregator hubs (Zomato kitchen-clusters, Swiggy hubs)
  • Standalone parking-lot or shopfront locations

Each site is either fixed-rental (typically ₹8,000-15,000 per month per station for a small footprint) or commission-based (typically 5-12 percent of swap revenue at the station). The reconciliation tracks per-station revenue, accrues the host payment at the agreed structure, and deducts Section 393 code 1009 (rental) or 1007 (commission) TDS at outbound payment.

Where subscriptions are sold via a delivery-aggregator app, the aggregator is paid a marketing or activation commission per onboarded rider. This is Section 393 code 1010 TDS at 1 percent.

Rail 4 — End-of-life battery resale and scrap

When a battery is impaired below useful-life threshold, the BaaS operator has two disposal options:

  • Resale of used battery — to second-life use (residential energy storage, BTL applications), HSN 8507 at 18 percent GST as goods supply
  • Scrap recycling — to certified recyclers (Attero, Lohum, MetEx) under HSN 8548, with Section 394 code 1023 TCS at 1 percent on scrap value under Rule 55

The reconciliation maintains a disposal register tying each battery serial to its disposal route, sale invoice, GST classification and TCS deduction.

Interactive Tool

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Worked example — BaaS network with 4,200 batteries, 580 stations, May 2026

LineValue
Battery fleet at month-start4,200
Swap stations580
Active rider subscriptions38,500
Subscription revenue (38,500 × ₹999)₹3.85 Cr — recognised straight-line over May
Total swap events12.4 lakh
Per-swap fee revenue (above-bundle swaps)₹8.6 Cr — recognised at event
Total May revenue (gross)₹12.45 Cr
GST output at 18% SAC 998599₹2.24 Cr
Site-host commission accrual (commission stations)₹62 lakh
Site-host rental accrual (rental stations)₹84 lakh
Aggregator activation commissions₹18 lakh
Section 393 code 1007 TDS (2% on commission)₹1.24 lakh
Section 393 code 1009 TDS (10% on rental)₹8.4 lakh
Section 393 code 1010 TDS (1% on aggregator)₹18,000
Batteries impaired below recoverable18
Impairment loss recognised (Ind AS 36)₹14.4 lakh
Batteries sold for scrap recycling42
Scrap recovery value₹6.3 lakh
Section 394 code 1023 TCS at 1% on scrap₹6,300

The CFO’s month-end close ties the Ind AS 36 impairment to the per-battery CGU ledger, the Ind AS 115 revenue across subscription + per-swap, the GST output across both, and the three Section 393 TDS rails to outbound payments.

What does the Section 393 / GST overlay look like?

  • Section 393(1)(e) code 1009 — 10 percent TDS on fixed monthly rental to site hosts. See Payment Code 1009 — Rent on Land/Building.
  • Section 393(1)(f) code 1007 — 2 percent TDS on commission to site hosts paid as percentage of swap revenue. See Payment Code 1007 — Commission & Brokerage.
  • Section 393(1)(j) code 1010 — 1 percent TDS on activation commission to delivery-aggregator apps and fleet-management platforms. See Payment Code 1010 — E-commerce Operator Deduction.
  • Section 393(1)(a) code 1002 — where the BaaS operator bills a corporate fleet customer (Zomato, Swiggy fleet, Porter), the customer deducts 1-2 percent TDS under code 1002 on the gross invoice. The BaaS operator’s quarterly 26AS reconciliation chases this credit by customer TAN.
  • Section 394 code 1023 TCS — 1 percent TCS on scrap battery sales to recyclers under Rule 55.
  • GST output — 18 percent on subscription, 18 percent on per-swap fee, 18 percent on second-life resale (HSN 8507), 18 percent on scrap with TCS classification.
  • ITC — available on input electricity for charging (where the BaaS operator pays a discom tariff), input charger equipment, station fit-out, software platform, marketing.

For the broader payment-code reference see TDS payment codes 1001-1092 India and Section 393 framework explainer.

MHI authority reference

For the Battery Swapping Policy framework, interoperability standards under the BIS for swappable batteries, and the regulatory treatment of energy-as-a-service models for electric two- and three-wheelers see the Ministry of Heavy Industries (MHI), Government of India.

What automated reconciliation changes

Running a dual-rail BaaS reconciliation across 4,200 per-battery CGUs, 580 swap stations with three commercial structures, 38,500 active subscriptions, 12+ lakh monthly swap events, three Section 393 TDS codes plus Section 394 code 1023 TCS, and Ind AS 36 + Ind AS 115 concurrently is the most reconciliation-dense operating model in Indian EV financial operations. Purpose-built auto component reconciliation software India holds the battery-asset master with BMS-telemetry-driven impairment indicators, the per-swap-event ledger, the subscription billing engine, the site-host and aggregator settlement matchers and the multi-code TDS/TCS ledger in one frame. Customer outcomes include match rate improvement from 51 percent to 88 percent on revenue-grade ledgers. Build is two-to-four weeks on AWS Mumbai (ISO 27001:2022). For the inbound procurement match on battery cells, swap-station hardware and operating spares see three-way matching software India.

Continue reading

Primary reference: Ministry of Heavy Industries (MHI), Government of India — for the Battery Swapping Policy framework, interoperability standards under the BIS for swappable batteries, and the regulatory treatment of energy-as-a-service models for electric two- and three-wheelers.

Frequently Asked Questions

What is swappable battery-as-a-service and who are the dominant Indian operators?
Swappable BaaS separates battery ownership from vehicle ownership. The vehicle is sold to the end user (typically a gig-economy delivery rider or fleet operator) without a battery, at a materially lower upfront cost. The battery is owned by a BaaS operator who runs a network of swap stations where the rider exchanges a depleted battery for a charged one in 60-90 seconds. The rider pays a monthly subscription plus a per-swap fee. The dominant Indian operators as of FY 2026-27 are Sun Mobility (joint venture with SUN Group, active across multiple OEMs including Piaggio and Bajaj), Lithion Power (urban delivery focus, partnerships with Zomato and Swiggy fleets) and Battery Smart (largest by station count, 1,000-plus swap stations across 35-plus cities). The market is also seeing entry from oil-marketing companies (HPCL, IOC) running pilot swap networks at petrol pumps.
How is BaaS revenue commercially structured and recognised under Ind AS 115?
BaaS revenue is typically a two-component structure: a monthly subscription fee giving the rider access to the swap network and the right to a contracted number of swaps, plus a per-swap usage fee for swaps above the contracted bundle. Under Ind AS 115 the subscription is a continuous supply of services recognised over the subscription period (monthly), and the per-swap fee is point-in-time revenue recognised at swap event. The fixed monthly is GST-taxable under SAC 998599 at 18 percent under forward charge; the per-swap fee is also taxable at 18 percent at swap event. Where the BaaS operator also sells used or end-of-life batteries (after the Ind AS 36 impairment cycle takes them below useful-life threshold), the resale is a separate goods supply with its own GST treatment (typically 5 percent or 18 percent depending on the battery state).
How is the Ind AS 36 impairment cycle managed across thousands of batteries?
A BaaS operator's primary fixed asset is the battery fleet. Each battery is a separately tagged cash-generating unit (CGU) with a useful life of 4-7 years and a recoverable amount determined by usage cycles, depth-of-discharge history, internal resistance, capacity fade and end-of-life resale value. Ind AS 36 requires impairment testing whenever indicators are present — typically annually for the fleet as a whole, and more frequently for batteries showing degradation outliers detected by BMS telemetry. The impairment loss for a battery whose recoverable amount falls below its carrying value is recognised in profit or loss, and the carrying value is written down to the recoverable amount. The reconciliation maintains a per-battery CGU ledger with monthly capacity-fade data from BMS, cumulative swap-cycles, depth-of-discharge profile, and impairment-testing flags.
What is the GST treatment of subscription vs swap fee vs end-of-life battery resale?
Three distinct GST treatments apply concurrently: (1) monthly subscription — continuous supply of services under Section 13, SAC 998599 at 18 percent forward charge, with monthly tax invoice and ITC available to the rider where the rider is a registered fleet operator; (2) per-swap fee — point-in-time supply at swap event, also SAC 998599 at 18 percent, with daily or weekly aggregated invoicing; (3) end-of-life battery resale — sale of goods classified under HSN 8507 (electric accumulators) at 18 percent, or where the battery is sold as scrap for recycling under HSN 8548, treated as scrap supply with Section 394 code 1023 TCS at 1 percent under Rule 55. The reconciliation must hold the three streams ledger-separated.
What Section 393 TDS applies on BaaS operator payments to site hosts and aggregators?
A BaaS operator's swap stations are typically hosted at third-party locations — petrol pumps, kirana stores, delivery-aggregator hubs, parking lots — with a site-host rental or commission paid monthly. Where the host is paid fixed rental, it is Section 393(1)(e) code 1009 at 10 percent (legacy 194I). Where the host is paid commission as a percentage of swaps executed, it is Section 393(1)(f) code 1007 at 2 percent (legacy 194H). Where the BaaS subscription is sold via a fleet-management aggregator or a gig-economy app, payments to the aggregator are Section 393(1)(j) code 1010 at 1 percent (legacy 194O). The BaaS operator's quarterly Form 26AS reconciliation must hold these three TDS codes separately.

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