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Issues: Whether the IGST rate applicable to import of dialysis machines covered under HSN code 90189031 is 5% in terms of the office memorandum dated 13.10.2023, and whether the respondents could be bound by their statement on the issue.
Analysis: The respondents stated that dialysis machines covered under HSN code 90189031 are liable to IGST at 5% under the notification dated 13.10.2023, and that the petitioner's case would also attract the same rate subject to verification of the HSN code.
Conclusion: The rate of IGST for the petitioner's import of dialysis machines was accepted as 5% subject to verification of the HSN code, and the respondents were bound by their statement.