In re Kartik Pinakin Bhatt [Trade Name: Ace Multitechs] (GST AAR Gujarat)
The applicant, a GST-registered manufacturer based in Gujarat, sought an advance ruling regarding the classification and applicable GST rate on its range of mouth freshener products marketed under the brand “KAPSUL.” The products include Paan Kapsul (Silver Coated), Paan Kapsul (Regular), Paan Kapsul (Rose), ChatPata Twins, Tangy Twins, Ginger Shots, Amla Shots, and GasGo Candy. The applicant manufactures the first three products by mixing ingredients and filling them into edible plant-based capsules, while the remaining five products are purchased in finished form and only packed or repacked.
For Paan Kapsul variants, the ingredients include betel leaves, gulkand, raw supari (unscented), sugar syrup, flavored plant-fiber capsules, aniseeds, and menthol, with silver leaves additionally used in the Silver Coated variant. The manufacturing process involves mixing the ingredients into a homogeneous mass, filling them into capsules, inspection, and blister packaging. The other products contain ingredients such as dry mango powder, pudina, dry ginger, cumin, amla, salt, black pepper, and other spices. These are packed or repacked without further processing.
The applicant sought clarification on the appropriate HSN classification and GST rate, particularly since the raw materials attract different GST rates. During the hearing, samples were examined and detailed ingredient lists and manufacturing processes were submitted.
