Writ review is limited in advance ruling matters; marine paint remains a separate commodity, not a ship part.

Writ review of an advance ruling remains limited to jurisdictional error, perversity, or fundamental legal mistake, and the High Court will not reappreciate classification on merits where the statutory authorities have followed due process. Applying the GST rate notification, the Court held that marine paint is a distinct, standalone commodity falling under the paint entry and is not converted into a ship part merely because anti-fouling paint is required for lawful sailing. The petitioner's reliance on other precedents was distinguished on statutory and factual grounds. The advance ruling authorities' classification of marine paint was therefore upheld.

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Issues: (i) Whether the High Court could interfere in writ jurisdiction with the advance ruling and appellate advance ruling on the classification of marine paint. (ii) Whether marine paint used on ships is classifiable as a "part" of the ship under the GST rate notification.

Issue (i): Whether the High Court could interfere in writ jurisdiction with the advance ruling and appellate advance ruling on the classification of marine paint.

Analysis: The advance ruling mechanism under the GST law is a specialised statutory scheme with limited binding effect on the applicant and jurisdictional officers. The Court held that absence of a further appeal does not enlarge writ jurisdiction into a full appellate re-hearing on merits. The Authorities had followed the prescribed procedure, afforded hearing, and considered the petitioner's material. In such a situation, judicial review was confined to detecting a fundamental legal error, perversity, or a jurisdictional infirmity.

Conclusion: The challenge to the orders of the advance ruling authorities was not fit for interference in writ jurisdiction and was rejected.

Issue (ii): Whether marine paint used on ships is classifiable as a "part" of the ship under the GST rate notification.

Analysis: The classification dispute turned on the meaning of "part" in the rate notification. The Court accepted the Authorities' approach that the relevant enquiry was whether the product was an integral component of the ship for classification purposes, not whether the product was required by maritime law for lawful sailing. The Court held that marine paint is a separate, standalone commodity falling under the paint entry, and the statutory requirement to apply anti-fouling paint did not convert it into a ship part. The precedents relied upon by the petitioner were distinguished as arising in different statutory and factual contexts.

Conclusion: Marine paint was not held to be a "part" of the ship and was not entitled to classification under the entry for parts of ships.

Final Conclusion: The Court upheld the advance ruling authorities' classification view and declined to disturb the GST treatment of marine paint.

Ratio Decidendi: In writ review of an advance ruling, the Court will not reappreciate classification on merits where the statutory authorities have applied the correct interpretative test and the disputed product remains a distinct commodity rather than an integral part of the main goods.

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