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Issues: (i) Whether medicaments manufactured exclusively in accordance with authoritative homeopathic formulae, consisting of a single constituent, are classifiable under the prescribed tariff entry and the applicable GST rate. (ii) Whether medicaments so manufactured and consisting of two or more constituents are classifiable under the prescribed tariff entries depending on whether they are put up in measured doses or retail sale packing, and the applicable GST rate.
Issue (i): Whether medicaments manufactured exclusively in accordance with authoritative homeopathic formulae, consisting of a single constituent, are classifiable under the prescribed tariff entry and the applicable GST rate.
Analysis: The relevant tariff schedule treats homeopathic medicaments manufactured exclusively according to the authoritative books and sold under the specified name as goods of Chapter 30. On the Authority's reading, the single-constituent products manufactured by the applicant do not fall outside the Chapter 30 scheme and are covered by the entry applicable to homeopathic medicaments of the relevant tariff item.
Conclusion: The single-constituent medicaments are classifiable under tariff item 30049014 and attract GST at 2.5% CGST and 2.5% SGST.
Issue (ii): Whether medicaments so manufactured and consisting of two or more constituents are classifiable under the prescribed tariff entries depending on whether they are put up in measured doses or retail sale packing, and the applicable GST rate.
Analysis: Medicaments consisting of two or more constituents mixed together for therapeutic or prophylactic use are covered by tariff item 30039014 when they are not put up in measured doses or retail sale packing, and by tariff item 30049014 when they are put up in measured doses or in forms or packing for retail sale. In both situations, the Authority applied the same GST rate under the relevant Schedule I entry.
Conclusion: The two-or-more constituent medicaments are classifiable under tariff item 30039014 when not put up in measured doses or retail sale packing, and under tariff item 30049014 when put up in measured doses or retail sale packing, with GST at 2.5% CGST and 2.5% SGST in either case.
Final Conclusion: The applicant's homeopathic medicaments are entitled to classification under the specified Chapter 30 tariff items, with the applicable concessional GST rate determined by the form of presentation and retail packing as stated in the ruling.
Ratio Decidendi: Homeopathic medicaments manufactured exclusively according to the prescribed authoritative formulae are classifiable under Chapter 30 according to their composition and form of packing, and the applicable concessional GST rate follows the corresponding tariff entry in the rate schedule.