Motor vehicle seat parts stay in the residual tariff entry and attract GST at the lower rate.

Parts of seats of a kind used for motor vehicles remain classifiable under Tariff Heading 9401 and, specifically, under Tariff Item 9401 90 00, because the amended rate notification carved out only complete motor vehicle seats into the higher-rate entry while retaining "parts thereof" in the residual entry. On that basis, such parts attract GST at 18% under Serial No. 435A of Schedule III. The classification scheme, explanatory notes and contemporaneous circular were read together to confirm that only the seats themselves were shifted to the separate entry, not their parts.

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Issues: Whether parts of seats of a kind used for motor vehicles are classifiable under Tariff Heading 9401 as parts thereof and, if so, whether they attract GST at 18% under Serial No. 435A of Schedule III to Notification No. 1/2017-Central Tax (Rate) dated 28.06.2017, as amended.

Analysis: The relevant tariff scheme was read with the explanatory notes to Notification No. 1/2017-Central Tax (Rate) dated 28.06.2017 and the Customs Tariff classification structure. Tariff Heading 9401 covers seats and parts thereof, while Tariff Item 9401 20 00 specifically covers seats of a kind used for motor vehicles. The amended notification carved out seats of a kind used for motor vehicles into Serial No. 210A of Schedule IV, but the text of Serial No. 435A of Schedule III continued to cover parts thereof. The contemporaneous circular also confirmed the separate treatment of motor vehicle seats and the continued placement of parts thereof within the residual entry.

Conclusion: Parts of seats of a kind used for motor vehicles are classifiable under Tariff Heading 9401, specifically under Tariff Item 9401 90 00, and are chargeable to GST at 18% under Serial No. 435A of Schedule III.

Ratio Decidendi: Where a notification specifically carves out only complete motor vehicle seats into a higher-rate entry and retains the words "parts thereof" in the residual entry, such parts continue to fall in the residual lower-rate classification unless expressly excluded.

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