The Texas Comptroller of Public Accounts issued a decision partially granting the taxpayers’ refund requests for sales and use taxes paid on purchases from their vendor for components of a utility-scale solar power station during the relevant period. The taxpayers operate a commercial solar farm where solar panels convert sunlight into electricity, with the panels assembled into arrays with a tracker system from another company that moves the panels to maximize sunlight exposure. While the Comptroller agreed to partial refunds, the key dispute centered on whether the other company’s tracker system qualified for the manufacturing exemption, which the Administrative Law ...