Tariff classification of manually operated seed treatment drum falls under agricultural machinery, attracting GST at the prescribed rate.

A manually operated seed dressing, coating and treating drum was classified under HSN 8436 as agricultural machinery, not under HSN 8201 as a hand tool, because its function matched the HSN notes for seed dusting machines with a revolving drum used to coat seeds before sowing. The heading for hand tools did not apply merely because the equipment was manually operated. As the product fell under tariff item 84368090, it attracted GST at 12% under the corresponding rate notification entry.

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Issues: (i) Whether the manually operated seed dressing, coating and treating drum was classifiable under HSN 8201 as claimed by the applicant, or under HSN 8436 as other agricultural machinery; (ii) Whether the goods were liable to GST at nil rate or at 12% under the applicable tariff entry.

Issue (i): Whether the manually operated seed dressing, coating and treating drum was classifiable under HSN 8201 as claimed by the applicant, or under HSN 8436 as other agricultural machinery.

Analysis: HSN 8201 covers hand tools used independently in hand, whereas the subject product is a machine used for seed dressing, coating and treating seeds with chemicals before sowing. The relevant HSN notes for heading 8436 describe agricultural machinery including seed dusting machines with a revolving drum for coating seeds with insecticidal or fungicidal powders. The heading does not draw a distinction between manual and power-driven machines, and the product's function matched the description under heading 8436 rather than 8201.

Conclusion: The goods are not classifiable under HSN 8201 and are classifiable under HSN 8436, more specifically tariff item 84368090.

Issue (ii): Whether the goods were liable to GST at nil rate or at 12% under the applicable tariff entry.

Analysis: Since the goods fell under tariff item 84368090, the applicable rate was the one prescribed against the corresponding entry in the GST rate notification. The cited schedule entry covered the goods under the relevant tariff item.

Conclusion: The goods are liable to GST at 12%.

Final Conclusion: The ruling determines the product as agricultural machinery under tariff item 84368090 and not as a hand tool, thereby attracting GST at the prescribed rate under the rate notification.

Ratio Decidendi: For tariff classification under the HSN, the functional description in the relevant heading and the HSN notes govern classification, and a machine used for seed coating and treatment cannot be treated as a hand tool merely because it is manually operated.

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