Tariff classification of jet suit thrusters favours fans, not aircraft parts, under the most specific description rule.

The Authority for Advance Rulings, Karnataka held that the jet suit did not satisfy the statutory definition of an aircraft under the Aircraft Act, 1934, as no DGCA licence, registration or exemption for aircraft operation was shown. On that basis, the EDF Thrusters with Battery Pack were treated as electric ducted fans with the essential character of fans, not as parts of aircraft. Applying tariff classification principles and the rule that the most specific description prevails, the goods were classified under heading 8414, sub-heading 8414.5990, and not under heading 8807.

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Issues: Whether the supply of "EDF Thrusters with Battery Pack for Jet Suit" is classifiable as parts of aircraft under heading 8807 or as fans under heading 8414, and consequently the applicable HSN and GST rate.

Analysis: The application was admitted under the provisions dealing with classification of goods and determination of tax liability. The supply was examined in the context of the applicant's description of the jet suit as an aircraft and the claim that the EDF thrusters and battery pack were parts of such aircraft. The Authority held that the jet suit did not answer the statutory definition of aircraft under Section 2(1) of the Aircraft Act, 1934, and that no DGCA licence, registration, or exemption was shown for operation of an aircraft. The EDF units were found to be electric ducted fans working as a propulsion fan mechanism, and their essential character was that of fans rather than parts of aircraft. Applying the tariff interpretation principles and the principle that the most specific description prevails, the goods were held classifiable under heading 8414, specifically sub-heading 8414.5990.

Conclusion: The supply is not classifiable as parts of aircraft under heading 8807. It is classifiable as fans under HSN 8414.5990, and the applicable GST rate is 18%.

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