In re Amit Vinodkumar Kanjiya (GST AAR Gujrat)
M/s Amit Vinodkumar Kanjiya, trading as Akplast Packaging, manufactures plastic twine (sutli) from polypropylene (PP) or polyethylene (PE) granules for agricultural and industrial packing. The applicant was classifying the product under HSN 39239090 and charging 18% GST, but contended that it should instead fall under HSN 56074900, covering twine, cordage, ropes and cables of polyethylene or polypropylene. The applicant stated that GST had been charged at 12% before 22.09.2025 and at 5% thereafter, and sought an advance ruling on the correct HSN and GST rate. A personal hearing was held on 08.04.2026, following which the applicant submitted the manufacturing process on 09.04.2026. The process involved mixing PP/PE granules with masterbatch, extrusion, quenching, slitting into tapes, orientation through stretching, twisting and winding. The applicant submitted that the orientation and twisting process gave the product the character of twine and that Heading 5607 was more specific than Heading 3923.
The Authority considered the applicant’s submissions, the written submission of the Assistant Commissioner of State Tax dated 03.03.2026, the relevant Chapter Notes and HSN Notes under the Customs Tariff Act, 1975, and the provisions relating to Headings 3923, 3926 and 5607. The Authority noted that Chapter 39 excludes goods of Section XI, covering textiles and textile articles. However, it held that products manufactured from PP/PE granules, which are plastic materials classifiable under Headings 3901 and 3902, could not be treated as textile material merely because extrusion, slitting, orientation, twisting and winding processes were involved.
