Contradictory GST classification of bio-fertilisers led to setting aside the ruling and remand for fresh consideration.

Contradictory GST classification rulings on materially similar bio-fertiliser products justified fresh consideration. The appellate order had classified the products under Chapter 3002, but a later similar matter treated bio-fertilisers under Chapter 3105, creating an anomaly in approach. In view of this inconsistency, the classification decision was held unsustainable and was set aside. The matter was remanded to the appellate authority for reconsideration in accordance with law and the material on record, so that the proper tariff classification could be determined consistently.

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Issues: Whether the appellate advance ruling classifying the petitioner's bio-fertiliser products under Chapter 3002 could be sustained when a subsequent order in a similar matter took a contrary view, and whether the matter should be remanded for fresh consideration.

Analysis: The products were earlier held to fall under Chapter 3002, attracting GST at 12%, whereas in a later similar matter the appellate authority classified bio-fertilisers under Chapter 3105, attracting GST at 5%. The two orders therefore reflected contradictory approaches on substantially similar products. In these circumstances, the impugned classification order suffered from an anomaly and required reconsideration in the light of the later order and the material placed on record.

Conclusion: The impugned appellate ruling was quashed and the matter was remanded to the appellate authority for fresh consideration in accordance with law.

Final Conclusion: The petitioner obtained limited relief by securing setting aside of the impugned ruling and a fresh adjudication before the appellate authority.

Ratio Decidendi: Where materially similar goods are subjected to contradictory classification rulings, the earlier order may be set aside and remitted for de novo consideration to ensure consistency and lawful determination.

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