Advance ruling binding effect limited to applicant, while plastic-coated woven fabric was excluded from textile tariff headings.

The proviso to section 98(2) of the GST Act was held to apply only to the applicant before the AAR, so an earlier advance ruling in another person's case did not bar admission of the application. On classification, HDPE woven fabric coated or covered with LDPE or LLDPE melt was found not to retain textile character where the plastic coating was visible to the naked eye. It therefore did not fall under Heading 5903, and the tarpaulin made from it was also not classifiable under Heading 6306 or Heading 6301.

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Issues: (i) Whether the advance ruling application was barred by the proviso to section 98(2) of the GST Act because the same question had been decided in another applicant's case; (ii) Whether HDPE woven fabric coated or covered with LDPE or LLDPE melt used for tarpaulin manufacture is textile material classifiable under Heading 5903, and whether the resulting tarpaulin is classifiable under Heading 6306 or Heading 6301 of the Customs Tariff Act, 1975.

Issue (i): Whether the advance ruling application was barred by the proviso to section 98(2) of the GST Act because the same question had been decided in another applicant's case.

Analysis: The proviso to section 98(2) was construed as limited to the applicant making the application. The ruling rendered in another person's case was held not to bind a different applicant, because section 103(1)(a) restricts the binding effect of an advance ruling to the applicant who sought it and the concerned jurisdictional officer. The application was therefore held to remain admissible despite the earlier ruling on a similar question.

Conclusion: The application was not barred and was admissible.

Issue (ii): Whether HDPE woven fabric coated or covered with LDPE or LLDPE melt used for tarpaulin manufacture is textile material classifiable under Heading 5903, and whether the resulting tarpaulin is classifiable under Heading 6306 or Heading 6301 of the Customs Tariff Act, 1975.

Analysis: The classification turned on the effect of Section XI notes and Chapter 39. Woven fabric coated or covered on both sides with plastic material, where the coating is visible to the naked eye, was held not to retain the character of textile material. On examination of the samples and the manufacturing specifications, the product was found to be a composite of plastic and textile, but the visible coating/covering removed it from textile treatment. Since it was not textile material, it could not fall under Heading 5903 or be treated as tarpaulin made from textile material under Heading 6306. For the same reason, classification as a made-up textile article under Heading 6301 also did not arise.

Conclusion: The HDPE fabric coated or covered with LDPE or LLDPE melt was not textile material under Heading 5903, and the tarpaulin made from it was not classifiable under Heading 6306 or Heading 6301.

Final Conclusion: The ruling accepted the applicant's challenge on admissibility but rejected its classification claim, holding that the goods fall outside the textile headings sought and do not qualify as tarpaulin made from textile material.

Ratio Decidendi: A woven fabric coated or covered with plastic so that the coating is visible to the naked eye does not remain textile material for tariff classification, and an advance ruling binds only the applicant who sought it.

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