Agricultural implement classification: manually operated tree-climbing apparatus qualifies for GST exemption under the notified entry.

A manually operated aluminium tree-climbing apparatus designed with hooks for use in areca and pepper cultivation is treated as an agricultural implement because its design and actual use are specific to agricultural activity rather than general-purpose use. On that basis, the product falls under Tariff Heading 8201 and qualifies for exemption under Entry No. 137 of Notification No. 12/2017-Central Tax (Rate) for manually operated agricultural implements.

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Issues: Whether the product described as an agriculture tree climbing apparatus, unipole manually operated aluminium ladder, is classifiable as an agricultural implement under Tariff Heading 8201 and consequently exempt under the relevant GST exemption notification.

Analysis: The product was found to be a manually operated ladder with hooks intended for use in agriculture, particularly for climbing areca and pepper trees for spraying and harvesting. Its design and actual use showed that it was not a general-purpose ladder but a tool used specifically in agriculture. The classification was supported by the common parlance understanding of agricultural implements and by the cited authority treating a similar product as an agricultural implement. Goods falling under Tariff Heading 8201 are covered by Entry No. 137 of Notification No. 12/2017-Central Tax (Rate) dated 28.06.2017, which exempts agricultural implements manually operated or animal driven.

Conclusion: The product is an agricultural implement classifiable under Tariff Heading 8201 and is exempt under Entry No. 137 of Notification No. 12/2017-Central Tax (Rate) dated 28.06.2017.

Ratio Decidendi: A manually operated product used specifically and exclusively for agricultural activity is classifiable as an agricultural implement in common parlance and qualifies for exemption under the notified entry for Tariff Heading 8201.

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