Treated water exemption denied for industrial supply from CETP; treated as taxable under Schedule III at 18%.

Treated water obtained from a common effluent treatment plant was supplied for industrial use, not for public drinking purposes, so it did not qualify as exempt "water" under Serial No. 99 of Notification No. 2/2017-Central Tax (Rate), as amended. The appellate authority also declined to rely on a laboratory certificate first produced in appeal because accreditation of the laboratory and proper sampling were not established. Advance rulings cited by the applicant were not treated as binding precedents beyond the applicant and concerned officers, and the circulars relied on were distinguished as dealing with drinking water for public use or treated sewage water. The supply remained taxable at 18% under Serial No. 24 of Schedule III.

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Issues: Whether treated water obtained from a common effluent treatment plant and classifiable under Chapter 2201 was entitled to exemption as "water" under Serial No. 99 of Notification No. 2/2017-Central Tax (Rate), as amended, or was taxable under Serial No. 24 of Schedule III.

Analysis: The treated water was found to be supplied for industrial use and not for public drinking purposes. The appellate authority declined to rely on the laboratory certificate produced for the first time in appeal, noting the absence of proof that the laboratory was accredited and the absence of material showing proper sampling. The authority also held that advance rulings cited by the appellant did not assist it, as an advance ruling is binding only on the applicant and the concerned officers. The circulars relied upon were distinguished on the ground that they dealt with drinking water for public purposes and treated sewage water, and did not alter the conclusion reached on the facts of the present case.

Conclusion: Treated water obtained from the CETP was held not eligible for exemption under Serial No. 99 and was held taxable at 18% under Serial No. 24 of Schedule III. The appeal was not accepted and the impugned ruling was upheld.

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