Tariff classification of Papad Khar places its carbonate composition under GST, without extending papad's exemption to ingredients.
Papad Khar, manufactured from sodium chloride, sodium carbonate and sodium bicarbonate, is classified by its composition, manufacturing process and functional character under tariff item 28362090, rather than as salt under Heading 2501 or yeast or prepared baking powder under Heading 2102. It is treated as an inorganic carbonate preparation taxable at 18% GST under the applicable Schedule II entry. Exemption available to finished papad does not automatically extend to Papad Khar as an input or processing ingredient. Inputs and finished goods require independent tariff classification and tax treatment, and Papad Khar does not fall within the claimed exemption entries.
Issues: (i) Whether Papad Khar is classifiable under Heading 2501 or Heading 2102, or under tariff item 28362090, and its applicable GST rate; (ii) Whether Papad Khar qualifies for GST exemption as an ingredient used in exempt papad or under the stated exemption entries.
Issue (i): Whether Papad Khar is classifiable under Heading 2501 or Heading 2102, or under tariff item 28362090, and its applicable GST rate.
Analysis: Heading 2501 applies to salt and pure sodium chloride within the limited processing permitted by Chapter 25. Papad Khar is manufactured by mixing sodium chloride with sodium carbonate and sodium bicarbonate, followed by solidification, breaking and drying. Its composition and manufacturing process therefore do not satisfy the requirements for common salt, rock salt, or other products of Heading 2501.
Analysis: Heading 2102 is confined to yeasts, inactive single-cell micro-organisms and prepared baking powders. Papad Khar is neither yeast nor prepared baking powder: its alkaline carbonate and bicarbonate composition, utility and effect in preparing crisp traditional snacks are materially different. Its functionally active constituents are sodium carbonate and sodium bicarbonate, bringing it within the carbonate heading. Entry 35 of Schedule II to Notification No. 09/2025-Central Tax (Rate) applies to the product.
Conclusion: Papad Khar is not classifiable under Heading 2501 or Heading 2102. It is classifiable under tariff item 28362090 of the Customs Tariff Act, 1975 and is liable to GST at 18%; the finding is against the assessee.
Issue (ii): Whether Papad Khar qualifies for GST exemption as an ingredient used in exempt papad or under the stated exemption entries.
Analysis: Exemption of a finished product does not, by itself, extend to its raw materials or processing ingredients. Under the value-added tax framework, inputs and finished goods are independently classified and taxed according to their respective specific tariff entries and rate notifications. Papad Khar is not covered by the claimed exemption entries.
Conclusion: Papad Khar does not qualify for GST exemption under the claimed entries or on the ground that papad is exempt; the finding is against the assessee.
Final Conclusion: The product remains taxable as an inorganic carbonate preparation under the applicable Schedule II rate entry.
Ratio Decidendi: A product must be classified according to its composition, manufacturing process and functional character under the applicable tariff entry; exemption of a finished product does not automatically extend to its inputs.