GST classification of pattadar pass book turns on whether revenue records create title or merely evidence land entries.

For GST classification, a pattadar pass book cum title deed is not a document of title merely because it reflects land-record entries. The land-record framework shows that it is generated from record-of-rights and updated revenue records, while title is conferred by registered instruments or revenue certificates, not by revenue entries alone. Those entries may have evidentiary value, but they do not create title. The printed product therefore falls to be classified by the tariff description that matches its nature, and civil title dispute decisions do not control tariff classification. It is correctly classifiable under HSN 4820, not HSN 4907.

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Issues: Whether pattadar pass book cum title deed is a document of title classifiable under HSN 4907 or an article of stationery classifiable under HSN 4820 for GST purposes.

Analysis: The classification had to be determined by the nature of the article under the tariff entries and by the statutory character of the pattadar pass book under the land-record legislation. The court noted that the printing activity was a composite supply, but the dispute centered on whether the printed product itself answered the description of a document of title. The relevant provisions of the land-record law showed that the pass book is generated from record-of-rights entries and updated revenue records, while registered instruments or revenue certificates are the documents that confer title. Revenue entries may have evidentiary value, but they do not by themselves create title. The court also held that decisions arising in civil title disputes could not control tariff classification under the customs tariff entries.

Conclusion: The pattadar pass book cum title deed is not a document of title and is correctly classifiable under HSN 4820. The challenge to the advance ruling and appellate ruling failed.

Ratio Decidendi: A revenue-based pass book that merely records or reflects land entries does not become a document of title for tariff classification, and its GST classification must follow the tariff entry that accurately describes it.

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