Tariff classification of pulpwood turns on essential character, not end use; debarked wood falls under wood in the rough.

Debarked eucalyptus, acacia, casuarina and subabul wood supplied for pulping were classified under HSN 4403 as wood in the rough, not under HSN 4401 as wood waste and scrap. The ruling applied Chapter 44 of the Customs Tariff and held that the goods were neither fuel wood, chips or particles, sawdust, nor waste and scrap; removal of bark or splitting for use did not change their essential character. Classification depended on tariff description rather than end use, so pulpwood fitting HSN 4403 remained outside the HSN 4401 entry and attracted GST at the rate applicable to wood in the rough.

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Issues: Whether debarked eucalyptus wood, debarked acacia wood, casuarina wood and subabul wood supplied for pulping are classifiable under HSN 4401 as wood waste and scrap or under HSN 4403 as wood in the rough, and consequently the applicable GST rate.

Analysis: The goods were examined by reference to Chapter 44 of the Customs Tariff. HSN 4401 covers fuel wood, wood in chips or particles, sawdust, and wood waste and scrap. The pulpwood in question was found not to be fuel wood, not chips or particles, and not sawdust or waste and scrap. HSN 4403 covers wood in the rough, whether or not stripped of bark or sapwood, or roughly squared. The goods were held to answer that description, including where bark is removed or the wood is split for use, and therefore were not classifiable under HSN 4401.

Conclusion: The pulpwood is classifiable under HSN 4403 and not under HSN 4401. The applicable rate is 9% under the CGST Act and 9% under the KGST Act, with corresponding IGST at 18% for inter-State supply.

Final Conclusion: The ruling rejects the lower-tax classification claimed by the applicant and confirms that the supplied pulpwood attracts GST as wood in the rough under the relevant tariff entry.

Ratio Decidendi: Wood intended for pulping remains classifiable by its tariff character and not by its end use; where it fits the description of wood in the rough, it is excluded from the entry for wood waste and scrap.

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