GST classification of polypropylene leno bags treated them as plastic bags under HSN 3923, attracting 18% tax.

Polypropylene leno bags were classified as plastic bags under HSN 3923 for GST purposes because the applicable TRU clarification treated polypropylene woven and non-woven bags, including BOPP-laminated bags, as plastic goods rather than textile goods. The alternative claim for classification as sacks and bags of man-made textile materials under tariff item 6305 33 00 was rejected. On that basis, the bags attracted GST at 18% under tariff item 39232990.

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Issues: Classification of polypropylene leno bags for GST purposes and the applicable rate of tax.

Analysis: The product was claimed to be classifiable under tariff item 6305 33 00 as sacks and bags of man-made textile materials. The ruling instead relied on the TRU clarification in Circular No. 80/54/2018-GST, which states that polypropylene woven and non-woven bags, including bags laminated with BOPP, are to be treated as plastic bags under HSN 3923. The ruling also noted that HSN 3923 covers plastic sacks and bags, with tariff item 39232990 attracting 18% GST.

Conclusion: Polypropylene Leno Bags were held to be classifiable as plastic bags under HSN 3923 and liable to 18% GST.

Final Conclusion: The advance ruling answered the classification question against the applicant and fixed the tax treatment at the higher GST rate applicable to plastic bags.

Ratio Decidendi: Where a specific clarification treats polypropylene woven or non-woven bags as plastic bags under HSN 3923, that classification governs the GST rate despite an alternative claim based on textile tariff entries.

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