Agricultural implement exemption applies to manually operated tree pruners used for harvesting and related farm activity.

Tree pruners under HSN 82016000 were treated as agricultural implements because, in commercial and functional terms, they are manually operated pole tools with a knife used for harvesting areca, coconut and pepper and for related agricultural work. Applying the common parlance test, the AAR held that they fall within Tariff Heading 8201 and squarely within the exemption entry for agricultural implements manually operated or animal driven, including pruners of any kind. Their supply was therefore exempt under the relevant GST notification.

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Issues: Whether tree pruners covered by HSN 82016000 are agricultural implements manually operated or animal driven and whether their supply is exempt under the relevant GST exemption notification.

Analysis: The product was examined in its commercial and functional character and found to be a manually operated pole fitted with a knife, used for harvesting areca, coconut and pepper and for related agricultural activity. Applying the common parlance understanding of implements used in agriculture, the product was treated as an agricultural implement falling under Tariff Heading 8201. The entry in Notification No. 2/2017-Central Tax (Rate) specifically covers agricultural implements manually operated or animal driven, including pruners of any kind, and the product squarely fits within that description.

Conclusion: Tree pruners covered under HSN 82016000 are agricultural implements, and their supply is exempt under Entry No. 137 of Notification No. 2/2017-Central Tax (Rate) dated 28.06.2017.

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