Classification of "Bellow Ducts" for Indian Railway Coaches: GST Rate Decision

The Authority for Advance Ruling held that the supply of "Bellow Ducts" to the Ministry of Railways for use in Indian Railway Coaches should be classified under HSN 8424, attracting an 18% GST rate. The applicant's belief that the supply fell under Chapter 86 with a 12% GST rate was dismissed, as the product did not align with the categories specified under that chapter. The ruling is valid within the jurisdiction of the Authority for Advance Ruling Uttar Pradesh, subject to relevant provisions of the CGST Act, 2017.

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Issues:
Classification and GST rate on the supply of "Bellow Duct" to RDSO Ministry of Railways for use in Indian Railway Coaches.

Analysis:
The applicant, engaged in the supply of "Bellow Duct" for Indian Railway Coaches, sought an advance ruling on the HSN Code and GST rate for their product. The applicant believed that the supply falls under Chapter 86 of the CGST Rate Schedule, attracting a GST rate of 12%. However, the Jurisdictional GST Officer opined that the correct classification should be under sub-heading 8607, with a GST rate as per the present tariff. The applicant presented their case, emphasizing the relevance of Chapter 86 to their product.

Upon detailed examination, the Authority noted discrepancies between the applicant's product description and the Customs Tariff Act. The Customs Tariff Act classified Industrial Bellows under HSN 8424, which covers mechanical appliances for projecting liquids or powders. The applicant had considered HSN 8607 for their product, but this chapter pertains to parts of railway locomotives or rolling stock. The Authority highlighted that the applicant's product did not fit within the categories specified under Chapter 86.

Further, the Authority referred to Circular No. 30/4/2018-GST, clarifying that only goods classified under Chapter 86 and supplied to railways attract a reduced GST rate. Products falling under other chapters, even if supplied to railways, are subject to general GST rates. Therefore, the Authority concluded that the applicant's "Bellow Ducts" should be classified under HSN 8424, attracting an 18% GST rate. This ruling is valid within the jurisdiction of the Authority for Advance Ruling Uttar Pradesh, subject to relevant provisions of the CGST Act, 2017.

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