Parts used exclusively in fishing vessels classified under HSN 8902, attracting the concessional GST rate.

Goods specially manufactured and used as integral parts of fishing or floating vessels were treated as classifiable under HSN 8902 and covered by the concessional GST entry for parts of fishing vessels. The ruling relied on the fact that the items were used exclusively in the manufacture of fishing boats and floating vessels, and on earlier rulings that had applied the same classification to marine propellers, rudder sets, stern tube sets, propeller shafts, and similar components. The specified goods were therefore eligible for 5% GST under Entry 252 of the First Schedule to Notification No. 1/2017-Central Tax (Rate).

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Issues: Whether propeller, shaft or SS rod, gun metal bush or bearing, stuffing box, brass tube or SS tube, rudder shaft and blade, sea cork or water strainer, GM gate valve, MS pipe, propeller nut or GM nut, coupling, SS rods and square, SS flat, GM gland and ring, and MS plate used as parts of fishing or floating vessels were classifiable under HSN 8902 and taxable at 5% GST under Serial No. 252 of the First Schedule to Notification No. 1/2017-Central Tax (Rate) dated 28.06.2017.

Analysis: The ruling records that the goods in question were exclusively used in the manufacture of fishing boats and fishing or floating vessels. It was noted that earlier rulings had already held that marine propellers, rudder sets, stern tube sets, propeller shafts, and MS shafts for couplings used as parts of fishing or floating vessels fell under Entry 252 of the First Schedule and attracted 5% GST. The ruling further relied on Notification No. 1/2017-Central Tax (Rate), which places HSN 8902 fishing vessels and parts of goods of headings 8901, 8902, 8904, 8905, 8906 and 8907 under the concessional rate.

Conclusion: The goods were held to be parts of fishing or floating vessels falling under HSN 8902 and liable to GST at 5%.

Final Conclusion: The applicant succeeded on classification and tax rate, and the specified goods were granted the concessional treatment applicable to parts of fishing or floating vessels.

Ratio Decidendi: Goods specially manufactured and used as integral parts of fishing or floating vessels are classifiable with the vessel heading and attract the concessional GST entry applicable to that heading.

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