Purified water under GST: STP treated water with residual impurities remains exempt under entry 99.

STP treated water obtained after sewage treatment was held not to be "purified water" for the exclusion in entry 99 of Notification No. 02/2017-Integrated Tax (Rate). Applying the ordinary meaning of "purified", the authority found that water becomes purified only when it is made free from foreign or objectionable elements; although treatment removed suspended matter and pollutants, the water still contained bacteria, virus and E. coli. Reading the entry with noscitur a sociis and its apparent purpose, the ruling treated the supply as general-use industrial water rather than specialised purified water. It therefore remained eligible for exemption under entry 99.

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Issues: Whether STP treated water obtained after sewage treatment is "purified water" excluded from entry 99 of Notification No. 02/2017-Integrated Tax (Rate), or whether it remains taxable water under Schedule III.

Analysis: The expression "purified" was not defined in the GST law, so its ordinary meaning was applied. Water is purified when it is made pure or free from foreign, extraneous, or objectionable elements. The treated water, though subjected to physical and biological processes that removed suspended particles, grit and other pollutants, still contained bacteria, virus, E. coli and other impurities. It therefore did not become pure water. The surrounding words in the exclusion clause, read with the principle of noscitur a sociis, indicated specific kinds of water having specialised characteristics and uses, unlike the impugned treated water, which was supplied through pipelines and was capable of being used as general-purpose industrial water. The purposive approach also supported exemption, since the Government had not intended to tax water of general use and had clarified that non-sealed supply of drinking water for public purposes was exempt.

Conclusion: STP treated water is not "purified water" for the purpose of the exclusion in entry 99 and is eligible for exemption from GST under that entry.

Ratio Decidendi: Water remains exempt under entry 99 where, despite treatment, it is still water of general use and has not been rendered pure water free from foreign or objectionable elements.

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