5% GST on Wooden Pooja Mandirs, 18% on Cradles and Wall Clocks: Tamil Nadu AAR

In re Wakato Bussan Enterprises (Sri Sakthikumar Ramakrishna) (GST AAR Tamil Nadu)

Summary: Sri Sakthikumar Ramakrishna, trading as M/s Wakato Bussan Enterprises in Chennai, sought the HSN classification and GST rates for six products proposed to be manufactured by skilled artisans using wood carving, turning, inlay and manual finishing. The Tamil Nadu Authority for Advance Ruling admitted the application under Section 97(2)(a) and (e) of the CGST Act, 2017 and the corresponding provisions of the TNGST Act. The State authority reported no pending proceedings on the questions raised. The AAR assumed the same position for the Central authority, from which it had received no remarks.

The applicant claimed 5% GST on the full range under Chapter 44, arguing that the products derived their essential character from their ornamentation and workmanship under General Interpretative Rule 3(b). It cited the trade practices of Poompuhar Handicrafts and Cauvery Emporium. At the hearing on 7 July 2026, its representative produced a pooja mandapam and a wooden wall clock bought from Poompuhar, together with invoices charging 5% GST. The AAR applied Rule 1 of the General Rules for Interpretation, which requires classification according to the tariff headings and the relevant Section and Chapter Notes.

The AAR classified the pooja mandir or home temple under HSN 4420 at 5%. It found that the carved pillars, decorative arches, inlay and temple-style roof formed a devotional structure intended to house idols and conduct worship. It classified wooden idols and statuettes under HSN 44201100 or 44201900 at 5%, as heading 4420 expressly covers wooden statuettes and ornaments. The wood-turned flower vases also attracted 5% under HSN 44209090 because their predominant decorative purpose brought them within the specific heading for wooden ornaments. The applicant had proposed the residual heading 4421 for the vases.

Wooden photo and mirror frames attracted 5% GST under HSN 44141000 for tropical wood and HSN 44149000 for other wood. The AAR left open the treatment under Section 8 of the CGST Act where a frame is supplied together with a mirror or artwork.

The AAR classified the wooden baby cradles under HSN 940350 as wooden bedroom furniture and ruled that they attract 18% GST. It applied Chapter Note 2 of Chapter 94, including the provision for beds designed to be hung, and Chapter Note 1(o) of Chapter 44, which excludes Chapter 94 articles. The operative ruling put wooden wall clocks under HSN 91052900 at 18% GST. The AAR found that their principal use was to display time and that Chapter Note 1(m) of Chapter 44 excludes goods of Section XVIII. Its reasoning distinguished electrically operated wall clocks under HSN 91052100 from other wall clocks under HSN 91052900.

The AAR accepted a Tamil Nadu Department of Commerce certificate dated 15 July 2026 identifying the applicant as a cottage-industry handicraft manufacturer. It held that the concessional entries in Notification No. 21/2018-Central Tax (Rate), as amended by Notification No. 13/2025-Central Tax (Rate), covered only headings 4414 and 4420 among the headings involved. The AAR applied Schedule II of Notification No. 09/2025-Central Tax (Rate), placing the wooden cradles under entry 612 for other furniture and the wall clocks under entry 587 for other clocks. Both attracted 9% CGST and 9% SGST. The four products covered by the concession attracted 2.5% CGST and 2.5% SGST.

FULL TEXT OF THE ORDER OF THE AUTHORITY FOR ADVANCE RULING, TAMIL NADU

M/s Wakato Bussan Enterprises, having place of business at Building no. 8/2, K.K. Road 4th Street, Venkatapuram, Ambattur, Chennai, Tamil Nadu – 600 053 (hereinafter called as the “Applicant”) has registered with GSTIN 33AUKPR7586C1Z9 under the Goods and Services Tax Act. They have filed this application for advance ruling under Section 97 of the CGST Act, 2017, and corresponding provisions under Section 97 of TNGST Act, 2017. The Applicant has made a payment of application fees of Rs.10,000/- under sub rule (1) of Rule 104 of CGST Rules, 2017 and TNGST Rules, 2017.

2. Statement of relevant facts having a bearing on the questions raised.

i. Nature of Manufacturing Activity

• • The Applicant is setting up a new manufacturing unit specifically dedicated to the production of high-quality Wooden artware and handcrafted items.
  • The Applicant’s primary method of production is Skill-intensive, relying heavily on traditional techniques such as detailed wood carving, wood turning (lathe work), and manual finishing carried out by skilled artisans.
  • The finished goods are valued primarily for their artistic, ornamental, and decorative quality, thereby placing the activity firmly within the ambit of the Handicraft Sector.

ii. Facts Specific to key products

• • Pooja Mandapam/Home Temple: These are highly decorative altars featuring significant hand-carving, inlay work, and intricate design. Much of the cost and value is derived from the artistry labour, and this product may be commercially treated as religious statuettes and ornamental article of wood.
  • Baby Cradles: These are manufactured using intricate Wood turning and carving techniques to create decorative components, confirming their artisanal character and distinguishing them from general wooden furniture.
  • Wooden Wall Clocks: The product may be considered as a decorative wall ornament or artware. The primary visual and cost-contributing component is the handcrafted wooden casing or frame (Chapter 44), involving carving, turning, and hand polishing.

iii. Market Classification Precedent

• • The other established government-run entities in the handicraft sector are already classifying and taxing similar products at the concessional rate.
  • Poompuhar Handicrafts (Tamil Nadu Govt.) sells these products under HSN code 4421 and 4420 at a GST rate of 5% (CGST 2.5% and SGST 2.5%)
  • Cauvery Karnataka state arts and crafts emporium also sells these products under HSN code 4421, 4403, 9503 and 4420 at a IGST rate of 5% (CGST 2.5% and SCGST 2.5%)

iv. The dominant characteristic and commercial identity of all their products lie in the fact that they are ornamental, artistic, and wood-based products (Chapter 44).

3. The applicant has filed the present application for advance ruling wanting to know the HSN code and GST rate of the products mentioned in the table below:

4. Applicant’s interpretation of law:

The applicant has submitted their interpretation of classification as below:

a. Core Interpretation: Applicability of Concessional Rate for Handicrafts:

The entire range of goods manufactured by them must be classified as bona fide wooden handicrafts, statuettes, or other ornamental articles of wood. Consequently, these goods are liable to be taxed at the concessional GST rate of 5 % (CGST 2.5% and SGST 2.5%) as notified by the Government under the relevant exemption notifications pertaining to the Handicraft Sector. The manufacturing activity involving skilled, wood carving, wood turning, and finishing, places the goods squarely within the scope of wooden artware and statuettes under Chapter 44 of the HSN.

b. Products-Specific Classification Argument

The classification of these products rests on the Rules for Interpretation of the Harmonised System (General Rules of Interpretation), specifically applying the concept of “essential character” (GRI 3(b)) over the functional use, given the ornamental nature of the product:

c. Reliance on Established Market Precedent

Applicant’s interpretation is supported by established practice within the sector:

• • • The government-owned handicraft enterprises, specifically Poompuhar Handicrafts (Tamil Nadu) and Cauvery Emporium (Karnataka); are already classifying and selling similar products (including home temples and decorative articles) under HSN 4420 and 4421 at the concessional 5% GST rate.
    • This demonstrates a clear industry and governmental understanding that the ornamental, carved, and wood-turned nature of these goods dictates classification in Chapter 44.

5. The applicant is under the administrative control of State. The concerned authorities of the Centre and State were addressed to report if there are any pending proceedings against the applicant on the issues raised by the applicant in the ARA application and for comments on the issues raised. Remarks have been received from the State Authority that there are no pending proceedings on the questions raised in their Advance Ruling Application. As remarks have not been received from Centre authority, it is assumed that there are no pending proceedings against the applicant on the issues raised by the applicant in the ARA application.

6. Personal Hearing

The applicant was given an opportunity to be heard in person on 07.07.2026. Shri. D.P. Durai Raj, Manager appeared for the personal hearing as the authorized representative (AR) of M/s. Wakato Bussan Enterprises. The AR reiterated the submissions made in their application for advance ruling. The AR also brought samples of Puja Mandapam and wooden wall clock purchased from Poompuhar (The Tamilnadu Handicrafts Development Corporation Limited), along with invoices wherein the GST rate of 5% has been adopted. The AR asked for Ruling as to whether the handicraft items proposed to be manufactured by them would be liable for GST @ 5%,

7. Discussions and Findings:

7.1. We have carefully examined the submissions made by the applicant in their advance ruling application and the submissions made during the personal hearing. We have also considered the issue involved, the relevant facts and the applicant’s submission / interpretation of law in respect of the questions on which the advance ruling is sought.

7.2. We find that the query is liable for admission as it gets covered under Section 97 (2) (a) and (e) of CGST/TNGST Act, 2017 under “Classification of goods and/or services or both” and “determination of the liability to pay tax on any goods or services or both”.

7.3. The applicant proposes to manufacture wooden handcrafted items viz., pooja mandapam/home temple, baby cradles, wall clocks, Idols/statuettes, photo/mirror frames and flower vases, involving the skill intensive process of turning, carving, inlay work and intricate design, and has sought to classify the items and specify the applicable GST rate. We first begin by analysing each of the said items in light of the suggested classification and arrive at the appropriate classification.

7.4. We note that Classification under GST is governed by the HSN as notified, applied in terms of the General Rules for the Interpretation (GRI) of the Customs Tariff (GRI), read with the Section Notes and Chapter Notes. Rule 1 of the GRI provides that classification is to be determined according to the terms of the headings and any relative Section or Chapter Notes, and only where the headings and notes do not otherwise require, resort gets made to the subsequent provisions.

7.5. The description of the products proposed to be manufactured by the applicant, and the classification as proposed by them are reproduced below:

7.6. We note that the HSNs that are involved in the classification sought by the applicant for the above articles are HSN 4414, 4420 and 4421. Before we proceed to check whether the above products fall under the HSNs, we note down the tariff description of the said HSNs, and then armed with the required information, we take up the products one by one.

a. HSN 4414

b. HSN 4420

c. HSN 4421

7.7. Pooja mandir/home temple :

a) We note that these are wooden pillared/domed structures, designed usually as a traditional temple, and offers space for placing idols, with/without doors, and shelves designed to house pooja essentials. The applicant has sought for the correct classification of the product and claimed that they fall under HSN 4420/4421.

b) Chapter 44 covers ‘wood and articles of wood’ in general and includes heading 4420 (Wood marquetry and inlaid wood; caskets and cases for jewellery or cutlery, and similar articles, of wood; statuettes and other ornaments, of wood; wooden articles of furniture not falling in Chapter 94.

c) The applicant has submitted images of Puja mandirs/ home temples proposed to be manufactured by them. They also brought a sample Puja mandir during the personal hearing. We find that a typical Puja mandir/ home temple proposed to be manufactured and sold by them is made of wood, resemble a miniature temple with a raised platform, have carved pillars, decorative arches, inlaid woodwork and a dome or gopuram-style roof. They come in different sizes, are intricately carved and polished, and meant to house idols and conduct worship.

d) The primary function of Puja mandir/ home temple is ritual housing of deities and conducting worship. We find that it’s a devotional/ornamental object made of wood, and not furniture meant for storage, seating, or general household utility. A puja mandir is sold and understood as a religious/decorative item and not as a piece of furniture. The mandirs are open-fronted shrine structures rather than enclosed storage units (cupboards/cabinets). We therefore find that Puja mandir/ home temple is suitable to be classified under HSN 4420 as an ornamental wooden structure, and not as a furniture falling in Chapter 94 (which covers articles designed to equip a room / office for practical use).

7.8. Baby cradles:

a) We note that cradles are small wooden beds specially designed for newborns and young infants, providing a safe, comfortable, and cozy place for sleeping and resting. They may or may not be designed to gently rock. The applicant has provided 2 images of the products that they propose to manufacture, and we find that they conform to the above description. The applicant seeks clarification on the classification of the above product and proposes classification under HSN code 4421.

b) We find that the baby cradles are made of wood, are movable articles, designed to be placed on the floor or suspended on a stand, and intended to provide a secure sleeping space for newborns and young infants, that fits easily beside a parent’s bed. It is therefore a wooden furniture of a kind used in the bedroom. As per Chapter note 2 of Chapter 94, articles designed for placing on the floor or ground are to be classified in those headings only. Also as per Chapter note 2(b) of Chapter 94, beds are to be classified in the above-mentioned headings-even if they are designed to be hung. We find that HSN 940350 covers Wooden furniture of a kind used in the bedroom. We therefore hold that baby cradle is classifiable under HSN 940350. Further, Chapter Note 1(o) of Chapter 44 states that the Chapter does not cover articles of Chapter 94. It therefore follows that baby cradles do not fall under Chapter 44 (and so under HSN 4421).

7.9. Wooden Wall Clocks:

a) The applicant has produced images of wooden wall clock that they propose to manufacture, and they also brought a sample of a clock during the personal hearing, We find that the ‘wooden wall clock’ is a time-measuring device designed to be mounted on a wall, in which the outer body, frame or casing is made of wood. It is used principally for displaying the time and may also serve as a decorative furnishing.

b) We first note that Chapter note 1(m) of Chapter 44 excludes goods of Section XVIII (for example, clock cases and musical instruments and parts thereof). The Chapter note clearly excludes an article that would otherwise appear to be a wooden article, but which functions as, or houses, a clock, out of Chapter 44, and directs the classification to Chapter 91. We therefore find that the Applicant’s reliance on heading 4420 is misplaced. The mere fact that the outer case is made of wood, does not bring a wall clock within Chapter 44.

c) We find that ‘Wall clock’ is covered under HSN 9105 as below:

d) We therefore find that a wooden wall clock of ordinary design — where the wood forms a conventional clock case/frame and the article is bought, sold, and used as a wall clock — is correctly classified under heading 9105 (sub-heading 9105 21 00 if electrically operated, or 9105 29 00 if not)

7.10. Idols of wood/ Statuettes:

a) The applicant has provided photos of different wooden idols/statues proposed to be manufactured by them. We find that the idols provided are of different gods/goddesses. We find that in general a wooden idol/statue is supposed to be a sculpted representation of a person, animal or figure, which may be artistic, commemorative, decorative or symbolic,

b) We note that Heading 4420 specifically covers “statuettes and other ornaments of wood” made of ‘tropical wood’ or ‘other’. HSN 4420, therefore covers carved wooden figures irrespective of whether they are devotional or decorative. No Chapter Note excludes idols or statuettes from this heading, and no more specific heading exists for such goods. The Idols of wood/ Statuettes are therefore indisputably classified under HSN 4420.

7.11. Wooden frames:

a) The applicant has stated that the wooden frames are decorative accessories, and are used for paintings, photographs and mirrors.

b) We find that Heading 4414 is a dedicated entry for “Wooden frames for paintings, photographs, mirrors or similar objects”. A wooden photo frame or mirror frame, whether plain, carved, inlaid, or gilded, is therefore classified under 44141000, if made of tropical wood, and under 44149000, if made of other type of wood. We further note that where a frame is supplied together with a mirror or artwork, the classification for GST purposes may need separate consideration under Section 8 of the CGST Act, a question not raised in the present application and left open.

7.12. Handcrafted flower vases:

a) The applicant states that the flower vases are wood turned and decorative domestic articles. In common parlance, a wooden flower vase is a decorative article crafted to hold and display flowers, ornamental foliage, or decorative arrangements. Its principal function is for indoor decorative use in homes, offices, hotels, temples, restaurants, and other commercial establishments.

b) Chapter Heading 4420 specifically covers “statuettes and other ornaments, of wood.” Heading 4421 is a residuary heading applicable only when an article is not more specifically covered elsewhere. Applying Rule 1 of the GRI, since a specific heading prevails over a general or residuary heading, it seems more appropriate that the articles whose predominant purpose is decoration are classifiable as ornaments rather than under the residual category of “other articles of wood.” It therefore follows that since Heading 4420 specifically covers wooden ornaments, classification of wooden flower vase under Heading 4421 is unwarranted. Consequently, a wooden flower vase is appropriately classifiable under HSN 44209090 as “Other” under the category of wooden ornaments.

7.13. Applicability of GST rates:

a) Having discussed and decided on the classification of the above products as consolidated in the table below, we now find out the appropriate GST rate applicable to each one of them:

b) We note that Notification No. 1/2017-Central Tax (Rate), dated 28 June 2017 (as amended from time to time), is the principal and governing GST rate notification for goods. Notification 09/2025-Central Tax (Rate) dated 17th September 2025, that supersedes the Notification No. 1/2017-Central Tax (Rate), dated 28 June 2017, notifies the rate of central tax of (i) 2.5 per cent in respect of goods specified in Schedule I and (ii) 9 per cent in respect of goods specified in Schedule II.

c) We also note that Notification No. 21/2018 -Central Tax (Rate) dated 26.07.2018, as amended by Notification No. 13/2025-Central Tax (Rate) provides exemption to handicraft goods. As per the above Notification, the expression “handicraft goods” means “Goods predominantly made by hand even though some tools or machinery may also have been used in the process; such goods are graced with visual appeal in the nature of ornamentation or inlay work or some similar work of a substantial nature; possess distinctive features, which can be aesthetic, artistic, ethnic or culturally attached and are amply different from mechanically produced goods of similar utility.”

d) We find that the applicant has provided a certificate bearing Row No. 5831 (Entry No. 1/A7/2026) dated 15.07.2026 from the Department of Commerce, Tamil Nadu, certifying that the applicant, being a manufacturer of “Handicraft Home temple, God idols etc.” falls under the category of Cottage industry — Handicraft goods manufacturer. We therefore note that products manufactured by the applicant are handicraft goods. However, we also note that out of the 6 products that we have in hand, falling under the HSNs 4414, 4420, 9105 and 9403, the Notification No. 21/2018 -Central Tax (Rate) dated 26.07.2018, as amended by Notification No. 13/2025-Central Tax (Rate) provides exemption to only the goods falling under HSNs 4414 and 4420, and prescribes the following Central GST rates:

e) With this information, we decide on the GST rates applicable to the products in question.

> Baby cradle: We have arrived that baby cradle falls under HSN 9403. As stated earlier, the said HSN is not covered under the exemption provided by the Notification No. 21/2018 -Central Tax (Rate) dated 26.07.2018 for Handicraft goods. Moving on to the Notification 09/2025-Central Tax (Rate) dated 17.09.2025, we note that HSN 9403 has entries in both the schedules I and II. We note that the entry bearing s.no. 490 in Schedule I is in respect of ‘furniture wholly made of bamboo, cane or rattan’, and the entry bearing s.no. 612 in Schedule II is in respect of ‘Other furniture [other than furniture wholly made of bamboo, cane or rattan] and parts thereof’. Since ‘baby cradle’ falling under 9403 are made of wood, we conclude that the same fall under s.no. 612 of Schedule II of the said Notification, and therefore the rate of central tax applicable to the said product is 9%.

> Wooden Wall Clocks: We have arrived at the conclusion that the wooden wall clock falls under HSN 9105. As stated earlier, the said HSN is not covered under the exemption provided by the Notification No. 21/2018 – Central Tax (Rate) dated 26.07.2018 for Handicraft goods. Moving on to the Notification 09/2025-Central Tax (Rate) dated 17.09.2025, we note that HSN 9105 is covered under s.no. 587 of Schedule II, and therefore the rate of central tax applicable to the said products is 9%.

> Puja Mandir, Idols of Wood/ Statuette and Handcrafted Flower Vases: We have arrived at the conclusion that the puja mandirs, Idols of Wood/ Statuette and Handcrafted Flower Vases fall under HSN 4420. As per the Notification No. 21/2018 -Central Tax (Rate) dated 26.07.2018, as amended by Notification No. 13/2025-Central Tax (Rate), the Central GST rate for HSN 4420– ‘ Statuettes And Other Ornaments, wood marquetry & Inlaid, Jewellery box, wood lathe and lacquer work [including lathe and lacquer work, ambadi sisal craft]’, and therefore for puja mandirs, Idols of Wood/ Statuette and Handcrafted Flower Vases is 2.5%.

> Wooden photo/Mirror Frames: We have arrived at the conclusion that the Wooden photo/Mirror Frames falls under HSN 4414. As per the Notification No. 21/2018 -Central Tax (Rate) dated 26.07.2018, as amended by Notification No. 13/2025-Central Tax (Rate), the Central GST rate for HSN 4414– ‘Wooden Frames for Paintings, Photographs, Mirrors or Similar Objects’, and therefore for Wooden photo/Mirror Frames is 2.5%.

8. In view of the above, we rule as under:

Ruling

Question: What is the HSN code and GST rate for the products Pooja Mandir/Home Temple, Baby Cradles, Wooden Wall Clocks, Idols of Wood/ Statuettes, Wooden photo/Mirror Frames and Handcrafted Flower Vases

Answer: The HSN codes and GST rates applicable to the products in question, is as in the table below: