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The AAR held that particulate matter permits are tradable goods, not securities, and are classifiable under HSN Heading 4907 (residuary code 4970 00 90). Applying ejusdem generis, the Authority rejected treating PM-permits as akin to bonds, stocks or debentures. The permits confer transferable economic benefits, have market value, are auctioned on the designated trading platform and may be sold for profit; accordingly proceeds constitute business income and sales are in the course or furtherance of business. Restrictions on transferability or expiry do not alter their character as goods. The applicable GST rate on trading of PM-permits is 12%.
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