Tariff classification of accumulator parts falls under heading 8507, attracting the GST rate for that heading.

Plastic rope handles, vent plugs and split top or bottom supports used as parts or accessories of electric accumulators are classifiable under heading 8507, because Chapter Note 2(s) to Chapter 39 excludes articles of Section XVI and the heading must be read with the relevant Section and Chapter Notes. Rule 1 of the General Rules for Interpretation was sufficient on the facts, so resort to Rules 2 and 3 was unnecessary. Once classified under heading 8507, the goods attracted the GST rate applicable to that heading under the relevant notification, namely 14% CGST and 14% SGST.

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Issues: (i) Whether rope handle, vent plug and split top / bottom support made of plastic are classifiable under heading 3926 or heading 8507; (ii) what rate of GST applies to the said products.

Issue (i): Whether rope handle, vent plug and split top / bottom support made of plastic are classifiable under heading 3926 or heading 8507.

Analysis: The goods were found to be plastic articles manufactured for use as parts or accessories of electric accumulators. Though heading 3926 broadly covers other articles of plastics, Chapter Note 2(s) to Chapter 39 excludes articles of Section XVI. The goods were held to fall within Section XVI because they are used with electric accumulators, and the relevant heading 8507, read with its notes, covers electric accumulators and parts thereof. The Authority held that Rule 1 of the General Rules for the Interpretation of the First Schedule to the Customs Tariff Act, 1975 governs the classification and that recourse to Rules 2 and 3 was unnecessary on the facts.

Conclusion: The goods are classifiable under heading 8507 and not under heading 3926.

Issue (ii): What rate of GST applies to the said products.

Analysis: Once the goods were classified under heading 8507, they attracted the rate applicable to that heading under Notification No. 1/2017-Central Tax (Rate) dated 28.06.2017 and the corresponding State notification. The Authority applied Serial No. 139 of Schedule IV for goods falling under heading 8507.

Conclusion: The applicable rate is 14% CGST and 14% SGST.

Final Conclusion: The impugned products were treated as parts of electric accumulators classifiable under heading 8507, with GST chargeable at the rate applicable to that heading.

Ratio Decidendi: For tariff classification, the terms of the heading must be read with the relevant Section and Chapter Notes, and goods excluded from Chapter 39 by Chapter Note 2(s) and used as parts of electric accumulators are classifiable under heading 8507 rather than as general plastic articles under heading 3926.

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