GST advance ruling cannot conclusively biodegradability or compostability; concessional rate for plastic bags remained unavailable on the records produced.

Compostable plastic bags were treated as plastic articles under Chapter 39 notwithstanding their claimed biodegradable character, so the concessional entry for biodegradable bags could not be applied on that basis alone. The Appellate Authority held that biodegradability and compostability are scientific and technical questions to be determined by competent environmental authorities, not conclusively by a GST advance ruling forum under Section 97(2) of the CGST Act. As the records and certificates produced were insufficient to displace that technical assessment, the authority upheld the Advance Ruling and rejected the appeal, while noting that the GST field formation may obtain samples and testing for verification.

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Issues: Whether the Appellate Authority was required to interfere with the Advance Ruling on eligibility of the applicant's compostable plastic bags for the concessional rate under Serial No. 319 of Notification No. 09/2025-Central Tax (Rate) dated 17.09.2025, and whether the authority under GST could itself conclusively determine biodegradability or compostability.

Analysis: The bags were held to fall under Chapter 39 as plastic articles, irrespective of their biodegradable character. The concessional entry applied only to biodegradable bags, but the determination of biodegradability and compostability was treated as a scientific and technical to be examined by the competent environmental authorities and not within the scope of advance ruling under Section 97(2) of the Central Goods and Services Tax Act, 2017. The records and certificates produced by the appellant were found insufficient for the Appellate Authority to substitute its own technical assessment, and it was observed that jurisdictional GST field formation may draw samples and obtain testing for that purpose.

Conclusion: The Advance Ruling was upheld and the appeal was rejected.

Ratio Decidendi: A GST advance ruling forum cannot itself conclusively determine biodegradability or compostability, which remains a technical question for the competent environmental authorities, and concessional entry eligibility linked to that condition cannot be granted on the basis of such technical determination alone.

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