Classification of highly technical goods under GST depends on the correct HSN based on tariff structure, interpretative rules, section notes, chapter notes, explanatory notes, functional character, composition, and relevant precedents. A reliable expert opinion requires full and frank disclosure of complete product particulars, including technical literature, manufacturing process, composition, functional analysis, end-use, samples, competing HSN treatments, tariff materials, judicial decisions, departmental circulars, and supporting certificates or laboratory reports where needed. The opinion is evidentiary rather than conclusive, and its value depends on the expert's qualifications, neutrality, methodology, and completeness of material examined. (AI Summary)
TaxTMI