Classification under GST and Customs law is a matter of legal interpretation grounded in tariff headings, section notes, chapter notes, the General Rules for Interpretation, HSN Explanatory Notes, judicial precedents, trade parlance, and the functional attributes of goods. Expert material may be relevant for understanding composition, design, operation, principal function, and essential character, but it remains explanatory only. Technical evidence cannot substitute statutory construction, override clear tariff language or binding precedent, and classification is ultimately determined by legal synthesis of technical facts with the tariff structure and interpretative rules. (AI Summary)
TaxTMI