GST classification of engineered quartz slabs follows their finished article character, not raw mineral composition, under HSN 6810.

GST classification of engineered Caesarstone turned on its manufacture and commercial identity rather than composition alone. Because the product was not imported as quartz in crude forms permitted under Chapter 25, and instead was made into slabs through mixing with resins and pigments, moulding, pressing, curing and polishing, it fell outside HSN 2506. The authority treated it as an article of artificial stone under HSN 6810, which specifically covered the finished product. The advance ruling was upheld and the goods remained classified under HSN 6810.

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Issues: Whether Caesarstone imported by the appellant is classifiable under HSN 2506 as quartz or under HSN 6810 as articles of artificial stone.

Analysis: Classification under GST is to be guided by the Customs Tariff and the HSN explanatory notes. HSN 2506 covers quartz only in its permitted forms under Chapter Note 1 to Chapter 25, and the product here was not imported as lumps or powder. The product was manufactured as an engineered slab using a mixture of natural quartz with resins and pigments, followed by moulding, pressing, curing and polishing, which went beyond the crude or mechanically processed state contemplated by Chapter 25. The appellant's reliance on composition alone and on the interpretation rules did not assist because the goods had acquired a distinct commercial identity and were not merely a mixture of quartz in crude form. By contrast, HSN 6810 covers articles of artificial stone, and the product's form and process of manufacture brought it within that heading and outside Chapter 25.

Conclusion: Caesarstone is classifiable under HSN 6810 and not under HSN 2506.

Final Conclusion: The appellate authority declined to interfere with the advance ruling and upheld the classification of the goods under HSN 6810.

Ratio Decidendi: Where a product is manufactured through processes beyond those permitted for Chapter 25 and acquires a distinct commercial identity, classification must follow the heading that specifically covers the finished article rather than the heading for the raw material.

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