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Issues: (i) Whether the applicant's black mineral water branded "ALVA" is classifiable under HSN 22011010 under Heading 2201 of the First Schedule to the Customs Tariff Act, 1975; (ii) Whether the said product attracts GST at the rate applicable to Entry 146 of Schedule I of Notification No. 09/2025-Central Tax (Rate) dated 17.09.2025.
Issue (i): Whether the applicant's black mineral water branded "ALVA" is classifiable under HSN 22011010 under Heading 2201 of the First Schedule to the Customs Tariff Act, 1975.
Analysis: The product was found to be drinking water with added minerals, without added sugar, sweetening matter, flavouring agents, preservatives or other functional additives. The Chapter 22 notes and the HSN notes to Heading 2201 expressly cover waters, including natural or artificial mineral waters, not containing added sugar or other sweetening matter nor flavoured. The notes also recognise artificial mineral waters prepared from potable water by adding mineral salts or gases.
Conclusion: The product is classifiable under HSN 22011010 under Heading 2201 of the First Schedule to the Customs Tariff Act, 1975.
Issue (ii): Whether the said product attracts GST at the rate applicable to Entry 146 of Schedule I of Notification No. 09/2025-Central Tax (Rate) dated 17.09.2025.
Analysis: Once classified under Heading 2201, the product falls within Entry 146 of Schedule I, which covers waters, including natural or artificial mineral waters and aerated waters, not containing added sugar or other sweetening matter nor flavoured. The notification prescribes the applicable rate for that entry.
Conclusion: The product falls under Entry 146 of Schedule I of Notification No. 09/2025-Central Tax (Rate) dated 17.09.2025 and is liable to GST at 5%.
Final Conclusion: The ruling confirms both the tariff classification and the GST rate for the applicant's product as a mineral water covered by the specified tariff heading and corresponding notification entry.
Ratio Decidendi: Waters prepared with added minerals, but without added sugar, sweetening matter or flavouring, remain classifiable as mineral waters under Heading 2201 and attract the GST rate prescribed for that heading.
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