Sleeping bag classification under GST turns on specific tariff entries and quilted textile material treatment

A sleeping bag made of textile material, without feather or down filling, was classified under tariff item 9404 30 90 because Chapter 94 covers bedding articles and tariff item 9404 30 specifically covers sleeping bags. The reasoning distinguished the feather- or down-filled sub-entry from the residual entry for other sleeping bags, and applied the principle that the more specific description prevails over the general description. The article was also treated as falling within the quilted textile material category, making it chargeable to GST at the rate applicable to that entry under the relevant rate notification, as amended.

---

---

Issues: Whether the sleeping bag described in the application was classifiable under tariff item 9404 30 90 as an other sleeping bag made of quilted textile material, and the applicable GST rate thereon.

Analysis: The product was found to be made of textile material, without feather or down filling, and quilted only to keep the layers intact. Chapter heading 9404 covers bedding articles, and tariff item 9404 30 specifically covers sleeping bags, with 9404 30 10 for those filled with feathers or down and 9404 30 90 for the remaining sleeping bags. The relevant notification treated products wholly made of quilted textile materials separately, and the rule of interpretation required the more specific description to prevail over the general one. Applying these principles, the product fell within the category of quilted textile material and not within the feather or down entry.

Conclusion: The sleeping bag was held classifiable under Chapter Heading 9404 30 90 and chargeable to GST at the rate applicable to that entry under Notification No. 01/2017-Central Tax (Rate) dated 28.06.2017, as amended.

---