Six fuel injection pump parts classified under CTH 84139190 attract 18% IGST as residuary items

The AAR TN ruled that six parts of fuel injection pumps (Assy Head Rotor, X Roller Shoe Kit, TP Blade/Spring Kit, TP Liner, Kit Excess Piston, and Hyd head Assy) supplied by the applicant are classifiable under CTH 84139190 as "Parts of pumps - others" rather than under specific pump parts entries. The Authority determined these parts attract 18% IGST under the residuary rate entry since fuel injection pumps are classified under CTH 84133010 but their parts are not specifically covered in the 28% rate schedule, falling instead under the general 18% rate for items not classified elsewhere.

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Issues Involved:
1. Classification of parts of fuel injection pumps.
2. Applicable GST rate for the parts of fuel injection pumps.

Issue 1: Classification of parts of fuel injection pumps

The Applicant, a GST registrant engaged in the manufacture and supply of fuel injection pumps and parts, sought advance ruling on the classification of specific parts of fuel injection pumps. The parts in question include Assy Head & Rotor, X Roller & Shoe Kit, TP Blade/Spring Kit, TP Liner, Kit Excess Piston, and Hyd head Assy for Tata Ace. The Applicant currently classifies these parts under Tariff Heading 84139190 and discharges GST at the rate of 28%.

Upon examination, the Authority referred to the Customs Tariff Act, 1975, and the Harmonised Commodity Description and Coding System (HSN). The classification principles under the General Rules for Interpretation (GRI) of the Customs Tariff were applied. The relevant headings considered were CTH 8409 (parts suitable for use solely or principally with engines of heading 8407 or 8408) and CTH 8413 (pumps for liquids, whether or not fitted with a measuring device; liquid elevators).

The Authority concluded that fuel injection pumps are excluded from CTH 8409 and correctly classified under CTH 8413, specifically 84133010 for injection pumps for diesel engines. Consequently, the parts of fuel injection pumps are classified under CTH 84139190 (parts of pumps - others) since they do not fit into more specific sub-headings like 84139110 (parts of reciprocating pumps) or 84139130 (parts of other rotary pumps).

Issue 2: Applicable GST rate for the parts of fuel injection pumps

The Authority examined the applicable GST rate for the classified parts. The fuel injection pumps for diesel engines are covered under Schedule IV of the IGST Goods Rate Notification No. 01/2017, attracting a tax rate of 28%. However, this entry does not include parts of pumps.

After verifying the Schedules of the Notification, the Authority found that the parts of pumps classified under Heading 84139190 are not covered by any specific entries in Schedule I, II, IV, V, or VI. Therefore, they fall under the residuary entry in Schedule III, which attracts 18% IGST.

Ruling:

1. The parts of fuel injection pumps, namely Assy Head & Rotor, X Roller & Shoe Kit, Kit Excess Piston, Hyd head Assy for Tata Ace, TP Blade/Spring Kit, and TP Liner, are classifiable under CTH 84139190 and taxable under SI. No. 453 of Schedule III of Notification No. 01/2017-Integrated Tax (Rate) dated 28.06.2017, attracting 18% IGST.

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