TaxTMI 
TaxTMI 
2026 (2) TMI 989
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..... The issue raised by M/s MAXGRADE PRIVATE LIMITED, 1/57, Kanakpura RIICO Industrial Area, Sirsi Road, JAIPUR-302034, Rajasthan (hereinafter "the applicant") is fit to pronounce advance ruling as they have deposited prescribed Fee under CGST Act and it falls under the ambit of the Section 97(2) given as under: (a) classification of goods and/or services or both (e) determination of the liability to pay tax paid or deemed to have been paid (g) whether any particular thing done by the applicant with respect to any gods and/or services or both amounts to or results in a supply of goods and/or services or both, within the meaning of that term A. SUBMISSION OF THE APPLICANT (in brief):- Brief facts of the case: Applicant is engaged in the manufacturing and supply of customized, made-to-order photo products. He seek an advance ruling on the appropriate classification and applicable HSN codes under the CGST and SGST Acts for the following products: a) UV Printed Acrylic Photo Frame • Product: Flat acrylic sheet (3-10mm) UV printed with customer-supplied photograph • Intended use: Wall-mounted decorative personalized....
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....cally operated) is correct? Q-3 Whether classification for MDF Keychain with Printed Photo under HSN 442199 (other articles of wood) is correct or whether it should fall under gift novelty items. D. COMMENTS OF THE JURISDICTIONAL OFFICER:- Comments received from the Office of Joint Commissioner, State Tax, Circle-D, Zone-JAIPUR-III, Divisional Kar Bhawan, Jhalana dungri, JAIPUR, Rajasthan vide letter No. स.आ./डी/तृतीय/2025-26/ 155 dated 12.08.2025 are as under: S.No. Question Raised by Applicant Taxpayer's Facts & Interpretations Legal Analysis & Justification (Tariff Headings, Notes, Notification) Conclusion & GST Rate 1 Whether UV Printed Acrylic Photo Frame should be classified under HSN 39269099 or under Chapters 49/97 • Product: Flat acrylic sheet (3-10 mm) UV printed with customer's photograph. • Marketed as personalized decorative item, made-to-order. • Believes classification may depend on end-use as a personalized photo product rather than raw material. Tariff Heading 3926: Covers "Other articles of plastics." Subheading 39269099: Residual f....
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....n already made by them. F. DISCUSSIONS AND FINDINGS 1. We have carefully examined the statement of facts, the application filed by the applicant, the submissions made during the hearing, and the comments from the jurisdictional Tax Authority. We also considered the issues involved for which the advance ruling is sought, along with other relevant facts. 2. The applicant M/s Maxgrade Private Limited is a firm/company and is registered with the GST department having GSTIN 08AANCM1404A1ZZ. The applicant engaged in the manufacturing and supplying of customised, made-too-order photo products. The applicant deal in products like UV Printed Acrylic Photo Frame, UV Printed Acrylic Wall Clock and MDF keychain with printed photo. 3. The applicant submitted that all the products are made-to-order and made by using high resolution UV printing. They are marked and sold primarily as customized gifts and photo memorabilia, not as generic plastic or wood items. The manufacturing process involves imported UV printers, custom art work generation and photo editing. They also submitted that they are classifying these items by the raw materials used in these items. 4. We proceed to examin....
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.... 3926 90 49 ---- Other --- Retroreflective sheeting of other than of heading 3920: 3926 90 51 ---- Of polyurethane foam 3926 90 59 ---- Other --- Hangers: 3926 90 61 ---- Of polyurethane foam 3926 90 69 ---- Other --- Plastic or nylon tipped hammers; insulating liner of nylon, HDPE: 3926 90 71 ---- Of polyurethane foam 3926 90 79 ---- Other 3926 90 80 --- Polypropylene articles, not elsewhere specified or included --- Other: 3926 90 91 ---- Of polyurethane foam 3926 90 99 ---- Other 6.1 Relevant portion of the Chapter notes of Chapter 39269099 read as under: This heading covers articles, not elsewhere specified or included, of plastics (as defined in Note 1 to the Chapter) or of other materials of headings 3901 to 3914. They include: (i) Articles of apparel and clothing accessories (other than toys) made by sewing or sealing sheets of plastics, e.g., aprons, belts, babies' bibs, raincoats, etc. Detachable plastic hoods remain classified in this heading if presented with the plastic raincoats to which they belong....
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....r notes of Chapter 49 read as under: 1. This Chapter does not cover: (a) photographic negatives or positives on transparent bases (Chapter 37); plans or globes, in relief, whether or not printed (heading 9023); (b) maps, (c) playing cards or other goods of Chapter 95; or (c) Playing cards or other goods of chapter 95 or (d) original engravings, prints or lithographs (heading 9702), postage or revenue stamps, stamp-postmarks, first-day covers, postal stationery or the like of heading 9704, antiques of an age exceeding one hundred years or other articles of Chapter 97. 2. For the purposes of Chapter 49, the term "printed" also means reproduced by means of a duplicating machine, produced under the control of an automatic data processing machine, embossed, photographed, photocopied, thermocopied or typewritten. The chapter heading 4911 covers all printed matter (including photographs and printed pictures) of this Chapter (see the General Explanatory Note above) but not more particularly covered by any of the preceding headings of the Chapter. In the case of framed pictures and photographs, frames which are of a kind and of a v....
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....s. (v) (A) Subject to Notes 1 to 4 above, articles of this Chapter are to be classified in this Chapter and not in any other Chapter of this Schedule. (B) Heading 9706 does not apply to articles of the preceding headings of this Chapter. (vi) Frames around paintings, drawings, pastels, collages or similarly decorative plaques, engravings, prints or lithographs are to be classified with those articles, provided they are of a kind and of a value normal to those articles. Frames which are not of kind or of a value normal to the articles referred to in this Note are to be classified separately. 8. We have gone through the relevant chapter Headings 39269099, 49119990 and Chapter 97 as well as the Chapter Notes pertaining to these headings detailed in paras-6 and 7 above and find that heading 39269099 is used for the product in which raw material is used as product of plastic. In UV printed acrylic photo frame, the sheet which is used is acrylic sheet and acrylic sheet is made by plastic. Further on study of chapter note, it is also observed that photo frame of acrylic sheet is nowhere mentioned in chapter heading 39. So, the applicant item UV printed Acryli....
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....p; Alarm clocks: 9105 11 00 Electrically operated 9105 19 00 Other Wall clocks: 9105 21 00 Electrically operated 9105 29 00 Other Other: 9105 91 00 Battery, accumulator or mains power 9105 99 Other: 9105 99 10 Time pieces 9105 99 90 Other 10.1 The relevant chapter note is as under: (i) This Chapter does not cover: (a) clock or watch glasses or weights (classified according to their constituent material); (b) watch chains (heading 7131 or 7117, as the case may be); (c) parts of general use defined in Note 2 to Section XV, of base metal (Section XV), or similar goods of plastics (Chapter 39) or of precious metal or metal clad with precious metal (generally heading 7115); clock or watch springs are, however, to be classified as clock or watch parts (heading 9114); (d) bearing balls (heading 7326 or heading 8482, as the case may be); (e) articles of heading 8412 constructed to work without an escapement; (f) ball bearings (heading 8482); (g) articles of Chapter 85, not yet assembled together or with other components into watch or clock ....
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.... For silk regenerated and synthetic fibre machinery 44219914 For other machinery 44219919 Other 44219920 Wood Paving Blocks 44219930 Match splints 44219940 Pencil slats 44219950 Parts of wood, namely oars, paddles and rudders for ships, boats and other similar floating structures 44219960 Parts of domestic decorative articles used as tableware and kitchenware 44219970 Articles of densified wood not included or specified elsewhere 44219990 Other 14.1 The relevant chapter note is as under: (i) This Chapter does not cover: (a) wood, in chips, in shavings, crushed, ground or powdered, of a kind used primarily in perfumery, in pharmacy, or for insecticidal, fungicidal or similar purposes (heading 1211); (b) bamboos or other materials of a woody nature of a kind used primarily for plaiting, in the rough, whether or not split, sawn lengthwise or cut to length (heading 1401); (c) wood, in chips, in shavings, ground or powdered, of a kind used primarily in dyeing or in tanning (heading 1404); (d) activ....