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Issues: Whether the products, namely Zip Roll, Finished Zipper and Slider, were classifiable under HSN 9607 as Slide Fasteners or Parts of Slide Fasteners, and the consequent GST rate applicable at the relevant times.
Analysis: Classification under GST was held to follow the Customs Tariff Act, 1975 and the HSN Explanatory Notes. Finished Zipper, being a complete article supplied in cut length with sliders attached, was treated as Slide Fasteners under heading 9607.11. Zip Roll, supplied in continuous length without sliders or runners, was treated as Parts of Slide Fasteners under heading 9607.20. Slider was also treated as Parts of Slide Fasteners under heading 9607.20. On the rate structure, the ruling noted that prior to 27.07.2018 both slide fasteners and parts thereof attracted a single GST rate of 18%, thereafter different rates applied until 30.09.2019, and from 01.10.2019 the entries again resulted in a single GST rate of 12% for both categories.
Conclusion: Finished Zipper was held to be classifiable as Slide Fasteners under HSN 9607.11, while Zip Roll and Slider were held to be classifiable as Parts of Slide Fasteners under HSN 9607.20. The corresponding GST rates were determined accordingly for the relevant periods.
Ratio Decidendi: For GST classification, the decisive test is the tariff description read with HSN explanatory material, and a product must be classified according to its actual character as a complete article or as a part thereof.