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Agricultural Seedling Trays made of Plastic manufactured by the Applicant are classifiable under CTH 39269099 and the applicable tax rate is 18%

Shanti Prime Publication Pvt. Ltd.

Classification of Goods — The Appeal is filed against the Order No. 16/AAR/2018 dated 27.09.2018 passed by the TamilNadu State Authority for Advance Ruling on the Application for Advance Ruling filed by the Appellant.

In the case at hand, the product, ‘Agricultural Seedling Tray’, is made up of Plastics and not of any of the base metals specified in the section notes as stated by the Appellant themselves. The contention of the Appellant is that the trays are used for germination of paddy and therefore, the product is to be considered as a ‘Hand tool used for agriculture’ and classified under 8201.

As per advance ruling authority Agricultural Seedling Trays made of Plastic manufactured by the Applicant are classifiable under CTH 39269099 and the applicable tax rate is 18%.

Held that—Classification under a Heading is to be governed only by the relevant Tariff-entries, Heading-description, etc. Heading 8201, as discussed above, do not envisage that all items used for agriculture would be covered therein but specifically as given in the General Explanatory Notes to Chapter 82, mentioned above, are to be classified based on the constituent material it is made of. We find that the lower authority has considered the above and accordingly pronounced the Ruling.—Saro Enterprises, In Re…. [2019] 09 TAXLOK.COM 078 (AAAR-Tamil Nadu)