TaxTMI 
TaxTMI 
2026 (5) TMI 875
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....in any added flavoring, added sugar, sweetening matter, preservatives or any other additives (lab reports confirm only mineral composition and standard physico-chemical parameters). 3. As per the laboratory analysis (Lab Report dated 17.09.2025), the product contains mainly calcium, magnesium, sodium at specified ppm levels. There are no added flavours, no added sugars/sweeteners, no preservatives and no other functional additives. The product is produced by the applicant by adding minerals to purified water at the manufacturing facility. The product is sold for human consumption as a packaged drinking water product and not sold as a medicinal product or as a food supplement. Photographs of the product as well as the copy of the lab report submitted by the applicant is reproduced here below: 4. The applicant manufactures the product at the manufacturing unit situated at Lodhikas, Rajkot, Gujarat, sells to distributors/retailers and also supplies to institutional buyers. Applicant collects GST and issues tax invoices for B2B and B2C supplies. 5. The applicant has asked the following question on Advance Ruling: 1. Whether the supply of our black mineral water with b....
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....n 08.04.2026 wherein Shri Bansi Sudhir Pandya, authorised representative appeared on behalf of the applicant and reiterated the facts & grounds as stated in the application. During the course of hearing, the representative has submitted flow charts marked as "Raw materials to product R.O. water" and flow charts showing processes carried out in Alkaline Water Plant, Black Alkaline Water Plant as well as flow chart regarding rinsing, filling & capping RFC plant. Images of the same are shown hereunder: FLOW CHART: RAW MATERIALS TO PRODUCT R.O. WATER Discussion and findings 8. At the outset, we would like to state that the provisions of both the CGST Act and the GGST Act are the same, except for certain provisions. Therefore, unless a mention is specifically made to such dissimilar provisions, a reference to the CGST Act would also mean a reference to the same provisions under the GGST Act. 9. We have considered the submissions made by the applicant in their application for advance ruling as well as the submissions made both oral and written during the course of personal hearing. We have also considered the issue involved, the relevant facts & the applicant's submission/ in....
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....rt of the applicant's product as well the various flow charts marked as "Raw materials to product R.O. water" and flow charts showing processes carried out in Alkaline Water Plant, Black Alkaline Water Plant as well as flow chart regarding rinsing, filling & capping RFC plant as appearing in paras - 3 & 7 above The lab report suggests that the sample of the product is "Drinking Water" and Black coloured liquid (black water). On going through the First Schedule to the Customs Tariff Act, 1975 (51 of 1975), we find that beverages are covered under Chapter 22 which covers "Beverages, spirit and vinegar" and drinking water/mineral water etc. being 'beverages', would fall under the said Chapter. Further, since the applicant has opined that the black mineral water with brand name "ALVA" manufactured and supplied by them is classifiable under HSN 22011010, we find it prudent to refer to the Chapter Notes of Chapter 22 of the First Schedule to the Customs Tariff Act, 1975 (51 of 1975), heading 2201 as per the Customs Tariff as well as the HSN notes of heading 2201. The same are reproduced below: CHAPTER 22: Beverages, spirits and vinegar NOTES: 1. This Chap....
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....ese waters varies considerably and they are generally classified according to the chemical characteristics of their salts, e.g.: (1) Alkaline waters. (2) Sulphated waters. (3) Halide waters. (4) Sulphuretted waters. (5) Arsenical waters. (6) Ferruginous waters. Such natural mineral waters may also contain natural or added carbon dioxide. Artificial mineral waters are prepared from ordinary potable water by adding the active principles (mineral salts or gases) present in the corresponding natural waters so as to produce waters of the same properties. The heading excludes sweetened or flavoured (orange, lemon, etc.) mineral \Vaters (natural or artificial) (heading 22.02). (C) Aerated waters (carbonated waters), i.e., ordinary potable waters charged with carbon dioxide gas under pressure. They are often called "soda waters" or "Seltzer" waters although tme "Seltzer" water is a natural mineral water. The heading excludes sweetened or flavoured aerated waters (heading 22.02). (D) Ice and snow, i.e., natural snow and ice, and artificially frozen water. The heading excludes edible ice of hea....
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....dule II; (iii) 20 per cent. in respect of goods specified in Schedule III; (iv) 1.5 per cent. in respect of goods specified in Schedule IV; (v) 0.125 per cent. in respect of goods specified in Schedule V; (vi) 0.75 per cent. in respect of goods specified in Schedule VI, and (vii) 14 per cent. in respect of goods specified in Schedule VII, appended to this notification (hereinafter referred to as the said Schedules), that shall be levied on intra-State supplies of goods, the description of which is specified in the corresponding entry in column (3) of the said Schedules, falling under the tariff item, sub-heading, heading or Chapter, as the case may be, as specified in the corresponding entry in column (2) of the said Schedules. Schedule I - 2.5% S.No. Chapter/Heading/Subheading/ Tariff item Description of goods (1) (2) (3) 146. 2201 Waters, including natural or artificial mineral waters and aerated waters, not containing added sugar or other sweetening matter nor flavoured. 15. On going through the aforementioned Notification, we find that Entry No.146 of Schedule I of Notification No. 09/2025-Ce....
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....e Packed in Plastic : N.M. Exp. Date : N.M Bottle Sample Condition B.No : N.M : Satisfactory Marking : Black Water Sample Drawn By : Customer Date of Starting of Test : 11/09/2025 Date of Completion : 17/09/2025 Sr No Test Parameters IS:10500 Requirement ( Acceptable Limit) IS: 10500 Permissible Limit In the Absense of Alternate Source Result Quan Limit Test Method Chemical Water 1 Colour Nol Prescribed Not Prescribed Black Colour Liquid 1 Visual 2 Odour Agreeable Agreeable Agreeable - IS:0025(P-5) 3 PH at 25 Deg C 6.5 lb 8.5 No Relaxation 7.09 1 IS:3025(P-11) 4 Taste Agreeable Agreeablo Agrecablo - IS:3025(P-7 & 8) 5 Turbidity, NTU Max. 1.0 Max. 5.0 0.1 IS:3025(P-10) Total Dissolved Solids, mg/ Max.500 Mox.2000 210 5 IS:3025(P-16) 7 Aluminium (as Al) mg/l Max.0.03 Max. 0.2 B.L.Q 0.01 IS:3025(P-55) 8 Anionic Surface active agents (as MBAS) mg/l Max. 0.2 Max. 1.0 B.L.Q 0.1 IS:3025(P-68) 9 Boron (as 8) mg/l Max.0.5 Max. 2.4 B.L.Q 0.05 IS:3025(P-57) 10 Calcium (as Ca), mg/l Max.75 Max.200 19.43 0.1 IS:3025(P-40) 11 Chloride (as Cl), mg/l Max.250 Max. 1000 87.84 0.5 IS:3025(P-32) 12 Fluonde (as F....
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....coli per 100 ml Shall not be Detectable Shall not be Detectablo Absent IS:15185 : 2016 | 32 Shall not be Delectablo Remark : Sample Found CONFORM as per IS: 10500-2012 (Acceptable Limit) with Amendment NO-4 for the tested parameters. Note : 1.1. - tiot Mentioned, B.L.Q. . Below Limit of Quantification FOR, GUJARAT TESTLAB PVT. LTD Mamta Dhavsar Hemal Darji-Krishna Amin Reviewed By Autho, Signatory For NABL Scope For Verification *** END OF REPORT · · · Document 2 Receipt of Packing materials Receipt of Raw Materials Pass Fail Storag Send Back to Supplier QC Inspect on QC Inspect on Fail Faillo- Pass Roject Raw water from bonewell stored In 2nos overhead storage tank (A) & {B) each WIneral Concentrate/TOTE and Dry Minerals Powder storage at Control Environment 5000L Raw Water Pump - 4.0 MPH - 3 Gar- CRI - 1.5 to 2.0 hp . Ill Phase E.M.F. System - Capacity. 4,000 LPH Pressure Sand Filter / Dua1 media filter (D.M.F) Cap. 02 m3/h Backwash water of liter - Activated carbon Filter Cap. 02 m3/hr Softner filter medla recharge tank mixed SALT used every B hr of tobl running ti....
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....P. Lined Micron Cartridge Filler20" - Regular - Spun - 0.45 Micron - 1 No. Alkaline Water Storage Tank - Readymade Food Grade Approved Tank ( C) . 2000 Liters X 2 Tanks along with Certificates BLACK WATER ALKALINE Tank (E) SYSTEM Transfer Pump - DS LIPH 0 35 Water - SS. Win Bypass System With Special Control Panel for Floaty For Both in Out Tanks for Auto Activation and Closure on Alarm banks Micron Cartridge Filter Housing 20" . Regular-S.S.316. F.R.P. Used Micron Cartridge Filter20" - Regular - Spun Micron Cartridge Filter Housing 20" - Regular . S.5.316. F.R.P. Lined Micron Cartridge Filter 20° - Regular - Spun . 5 Micron - 1 No. - 1 Micron - 1 Ha. Micron Cartridge Filter Housing 20" - Regular - S.S.316- .R.P. Lined Micron Cartridge Filter20" - Regular - Spun - 0.45 Micron - 1 No. U.V. System - 500 LPH - S.S. 316 with F.R.P. Lining - Product ALKALINE WATER TO RFC FLOW CHART : BLACK ALKALINE WATER PLANT Alkaline Water Storage Tank - Readymade Food Grade Approved Tank (E) - 2000 Liters X 2 Tanks along with Certificates Tank (E) TANK (D) Transfer Pump . 2.0 MPH @ 35 Meter . S.S. With Bypass System Cleaning In Place CIP. ....