Product classification under GST turns on exact fit with the notified description; proposed gypsum board was held outside GRG Board entry.

Classification under the GST rate notification depends on whether the goods squarely answer the notified description. The proposed gypsum board, though containing gypsum, glass fibre and additives, was treated as distinct from Glass-fibre Reinforced Gypsum Board because its composition and manufacturing identity did not match the notified product. On that basis, the entry for GRG Board did not cover the applicant's proposed product, and the concessional 12% GST rate under that entry was unavailable.

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Issues: Whether the new variant of gypsum board proposed to be manufactured by the applicant could be classified as Glass-fibre Reinforced Gypsum Board (GRG Board) and be subjected to GST at 12%.

Analysis: The product was examined with reference to its composition and the description of GRG Board in the rate notification. The ruling compared the proposed gypsum board, made from gypsum with glass fibre and additives, with GRG Board, which was treated as a different product in terms of its raw material base and manufacture. On that basis, the entry for Glass-fibre Reinforced Gypsum Board was held not to cover the applicant's proposed product. Since the product itself did not fall within the GRG description, the question of concession under the cited entry did not arise.

Conclusion: The proposed product is not Glass-fibre Reinforced Gypsum Board for the purpose of the notification and is not eligible for GST at 12% under that entry.

Ratio Decidendi: For classification under a tax entry, the product must squarely answer the description in the notification; if its composition and identity do not match the notified goods, the concessional rate cannot be claimed.

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