Tariff classification of rose water: ritual use does not override composition, and the product falls outside puja samagri exemption.

Rose water supplied as "Pooja Panneer" was held not to fall within the exempt category of puja samagri because the exemption entry is exhaustive, with "namely" limiting coverage to the specifically listed goods. The product was found to be prepared from synthetic rose perfume mixed with deionised or RO water, so it was not an aqueous distillate of essential oils under heading 3301 9060. Its actual composition placed it under heading 3301 9079 as a preparation of water and essential oil solution, and claimed ritual use or retail labelling did not change the tariff classification. The product was therefore outside the exemption and liable to GST.

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Issues: Whether rose water supplied as "Pooja Panneer" exclusively for puja or ritual use is classifiable under the exempt category of puja samagri, or under tariff heading 3301 9079 as an aqueous solution of essential oils liable to GST.

Analysis: The Authority held that the exemption entry for puja samagri under the relevant notification is exhaustive because the word "namely" confines the exemption to the specifically listed goods. Rose water is not among those listed items. The product was found to be made by mixing synthetic rose perfume with deionised or RO water, and therefore it is not an aqueous distillate of essential oils under heading 3301 9060. Since it is a preparation of water and essential oil solution, it falls under heading 3301 9079. The claimed puja use and retail labelling did not alter the tariff classification, and the product was not covered by the exemption for puja samagri.

Conclusion: The product is classifiable under HSN 3301 9079 and is taxable at 18% GST.

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