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Chilled Water Plant is not at all installed in any vessels, Submarines including Warship and Life Boats meant for Indian Navy, it cannot be categorised as “Any Parts” and subject to GST @ 5% under HSN 8906.

Classification of goods— In this case, moot points to be decided are the GST rate and HSN/SAC Code applicable to the “Supply, Testing and Commissioning of 160 TR Chilled Water Plant” to the Naval Dockyard (Vishakhapatnam). It is also to be decided as to whether supply of Chilled Water Plant can be categorised as “Any Parts” subject to GST @ 5% under HSN 8906. Held that— Since, said Chilled Water Plant is not at all installed in any vessels, Submarines including Warship and Life Boats meant for Indian Navy, it cannot be categorised as “Any Parts” of goods of headings 8901, 8902, 8904, 8905, 8906 & 8907. Consequently, said supply of the Chilled Water Plant will be out of ambit of the Entry at Sl. No. 252 of the Notification No. 01/2017-IT (Rate) dated 28.06.2017. Further, there is no exemption Notification issued under GST, which provides GST exemption in respect of Supply of 160TR Chilled Water Plant in question to the Naval Dockyard, Visakhapatnam, an Indian Naval Ship Repair Organisation of Indian Navy.