Purposive interpretation of residential house exemption: unregistered purchase agreement alone does not defeat relief, but investment must be verified...
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The AAR held that the puja samagri exemption is confined to the specific goods expressly listed in the notification, because the word "namely" makes the enumeration exhaustive. Rose water marketed as "Pooja Panneer" was therefore not exempt merely because it was used for ritual purposes or sold in devotional packaging. On tariff classification, the product was found not to be perfumes or toilet waters under heading 3303, and not an aqueous distillate obtained by steam distillation. On the material produced, it was classified as an aqueous solution of essential oils under tariff item 3301 9079 and subjected to GST at 18%.
The AAR held that the puja samagri exemption is confined to the specific goods expressly listed in the notification, because the word "namely" makes the enumeration exhaustive. Rose water marketed as "Pooja Panneer" was therefore not exempt merely because it was used for ritual purposes or sold in devotional packaging. On tariff classification, the product was found not to be perfumes or toilet waters under heading 3303, and not an aqueous distillate obtained by steam distillation. On the material produced, it was classified as an aqueous solution of essential oils under tariff item 3301 9079 and subjected to GST at 18%.
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