Link Up Textiles Private Limited (GST AAAR Tamilnadu)
The appeal was filed by the appellant under Section 100(1) of the Central Goods and Services Tax Act, 2017 and the Tamil Nadu Goods and Services Tax Act, 2017 against Advance Ruling No. 42/AAR/2025 dated 08.10.2025 issued by the Tamil Nadu Authority for Advance Ruling (AAR). The appellant, a private limited company registered under GST, is engaged in exporting men’s pyjama sets consisting of a top (kurta/shirt) and bottom (pyjama/trouser), made primarily of cotton with polyester and spandex. These products are packed as two sets in a single pack as per buyer requirements.
The appellant initially sought an advance ruling regarding the applicable HSN classification and GST rate for such goods, particularly where two pyjama sets are packed together and the total pack value exceeds ₹1,000. The AAR ruled that GST at 5% (2.5% CGST + 2.5% SGST) would apply where the sale value does not exceed ₹1,000 per piece, as per Sl. No. 223 of Schedule I of Notification No. 1/2017-Central Tax (Rate) dated 28.06.2017.
Aggrieved by this ruling, the appellant filed an appeal contending that the goods are marketed and sold as apparel “sets” and should be treated as a single retail unit. According to the appellant, under the General Rules for Interpretation (GIR 3(b)) and HSN Explanatory Notes, such coordinated apparel sold together qualifies as a “set for retail sale,” and therefore, the applicable GST rate threshold of ₹1,000 should be applied per set. The appellant further argued that the invoice and MRP reflect the set (or multi-pack) as the unit of sale, not individual garments, and that the effective value per set exceeds ₹1,000, thereby attracting GST at 12% (6% CGST + 6% SGST) under Schedule II.
