TaxTMI 
TaxTMI 
TaxTMI 
2025 (12) TMI 429
X X X X Extracts X X X X
X X X X Extracts X X X X
....n of material facts or misrepresentation of facts, shall render such ruling to be void ab initio in accordance with Section 104 of the Act. 5. The provisions of both the Central Goods and Services Tax Act and the Tamil Nadu Goods and Services Tax Act (herein referred to as the Act) are the same except for certain provisions. Therefore, unless a mention is specifically made to such dissimilar provisions, a reference to the Central Goods and Services Tax Act would also mean a reference to the same provisions under the Tamil Nadu Goods and Services Tax Act. M/s. Kaycee Industrial Chemicals Private Limited, No. 4/103, Saikanth Building, 3rd Street, Muthammal Colony, Thoothukudi - 628 002 (hereinafter called as the "Applicant") are registered under the GST Act with GSTIN 33AACCK1996Q1ZX. The applicant is engaged in manufacture of Quick Lime and Hydrated Lime. The applicant informed that they buy high purity limestone from Oman through importers and their agents; this limestone is burnt in a lime kiln wherein limestone gets converted to Quick Lime (CaO). The Quick Lime having 90% purity is sprayed with water to manufacture Hydrated Lime Ca(OH)2. The purity of Hydrated Lime ranges f....
X X X X Extracts X X X X
X X X X Extracts X X X X
....missioner (ST), Rajasthan State GST had issued a clarification which stated that hydrated lime having purity upto 98% falls under Heading 2522 and attract total GST @ 5%. Therefore, they are seeking an Advance Ruling in this regard. 5.1 The Members asked the AR to provide a write up on the process of manufacture and also details of composition of their final product for which the AR agreed to provide the same. The applicant, vide letter dated 27.09.2025 submitted a brief description of process of manufacture of Quick Lime and Hydrated Lime along with the compositions of both the products. 6) Discussions and Findings: 6.1 We have considered the submissions made by the applicant in their application, copies of the relevant documents furnished by them, the submissions made during the personal hearing. We find that the applicant, is engaged in manufacture of Quick Lime and Hydrated Lime. The applicant informed that they buy high purity limestone from Oman through importers and their agents; this limestone is burnt in a lime kiln wherein limestone gets converted to Quick Lime (CaO). The Quick Lime having 90% purity is sprayed with waver to manufacture Hydrated Lime Ca(OH)2. The....
X X X X Extracts X X X X
X X X X Extracts X X X X
.... 1975 (51 of 1975), including the Section and Chapter Notes and the General Explanatory Notes of the First Schedule shall, so far as may be, apply to the interpretation of this notification 6.8 Chapter 25 of the First Schedule to the Customs Tariff Act, 1975 covers Salt; sulphur; earths and stone; plastering materials, lime and cement. Heading 2522 of Chapter 25 reads as follows: 25.22 - Quicklime, slaked lime and hydraulic lime, other than calcium oxide and hydroxide of heading 28.25. 2522.10 - Quicklime 2522.20 - Slaked lime 2522.30 - Hydraulic lime * 6.9 As per the Explanatory Notes to Chapter 25 of the Customs Tariff Act, 1975 Quicklime (an impure calcium oxide) is obtained by calcining limestone containing very little or no clay. It combines very rapidly with water, giving off considerable heat and producing slaked lime (calcium hydroxide). Slaked lime is usually employed for soil improvement or in the sugar industry. Hydraulic lime is obtained by low temperature calcination of limestone containing sufficient clay (although usually less than 20 %) to ensure that the product sets under water. Hydraulic lime differs fro....
X X X X Extracts X X X X
X X X X Extracts X X X X
.... 68). In certain cases, however, the headings: (1) Refer to goods which by their nature must have been subjected to a process not provided for by Note I to this Chapter. Examples include pure sodium chloride (heading 25.01), certain forms of refined sulphur (heading 25.03), chamotte earth (heading 25.08), plasters (heading 25.20), quicklime (heading 25.22) and hydraulic cements (heading 25.23). (2) Specify conditions or processes which are admissible in those cases in addition to those allowed generally under Note I to this Chapter. For example, witherite (heading 25.11), siliceous fossil meals and similar siliceous earths (heading 25.12) and dolomite (heading 25.18) may be calcined; magnesite and magnesia (heading 25.19) may be fused or calcined (dead-burned (sintered) or caustic-burned). In the case of dead-burned (sintered) magnesia, other oxides (e.g., iron oxide, chromium oxide) may have been added to facilitate sintering. Similarly, the materials of headings 25.06, 25.14, 25.15, 25.16, 25.18 and 25.26 may be roughly trimmed or merely cut, by sawing or otherwise, into blocks or slabs of a rectangular (including square) shape. 6.12 Further, Chapter....
X X X X Extracts X X X X
X X X X Extracts X X X X
....s of a separate chemically defined compound combine in a specific characteristic proportion determined by the valency and the bonding requirements of the individual atoms. The proportion of each element is constant and specific to each compound and it is therefore said to be stoichiometric. Small deviations in the stoichiometric ratios can occur because of gaps or insertions in the crystal lattice. These compounds are described as quasi-stoichiometric and are permitted as separate chemically defined compounds provided that the deviations have not been intentionally created. 6.16 The applicant has claimed that the Hydrated lime supplied by them has 85% to 95% of Calcium Hydroxide, 3% to 13% of Calcium Carbonate and 2% Silica. Therefore, it is clear that the Hydrated Lime supplied by the applicant is not a separate chemically defined compound as intended in Chapter 28 of the Customs Tariff Act, 1975. The applicant is not supplying Calcium Hydroxide in the purest form, with negligible impurities, but Hydrated Lime with impurities to the level of 10% to 15%. 6.17 The heading 2825 covers Calcium Oxide and Calcium Hydroxide in the pure state i.e., containing practically no....