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AAR ruled PVC raincoats must be classified under HSN 3926 20 (plastic articles) rather than HSN 6201 (textile garments), attracting 18% GST. Though raincoats function as garments/apparel in common usage, their primary composition of polyvinyl chloride (PVC) determines classification. The authority rejected applicant's argument for textile classification, noting PVC sheets cannot be considered woven fabric or textile material. Following the principle of generalia specialibus non derogant, the specific material composition prevails over general garment usage. The ruling confirmed applicability of Schedule-III Entry 111 of GST notifications, regardless of the raincoat's price point, maintaining 18% rate uniformly.
AAR ruled PVC raincoats must be classified under HSN 3926 20 (plastic articles) rather than HSN 6201 (textile garments), attracting 18% GST. Though raincoats function as garments/apparel in common usage, their primary composition of polyvinyl chloride (PVC) determines classification. The authority rejected applicant's argument for textile classification, noting PVC sheets cannot be considered woven fabric or textile material. Following the principle of generalia specialibus non derogant, the specific material composition prevails over general garment usage. The ruling confirmed applicability of Schedule-III Entry 111 of GST notifications, regardless of the raincoat's price point, maintaining 18% rate uniformly.
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