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AAR Tamil Nadu Denies 5% GST as Compostable Bags Are Not Biodegradable

Case Law Details

TaxGuru Citation
2026 taxguru.in 10911
Case Name
In re Symphony Polymers Private Limted (GST AAR Tamilnadu)
Date of Judgement/Order
Only available for paid members
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In re Symphony Polymers Private Limted (GST AAR Tamilnadu)

M/s Symphony Polymers Private Limited, engaged in manufacturing and supplying compostable bags, packing materials, biodegradable bags and recycled products, sought an advance ruling under Section 97 of the CGST Act, 2017 and corresponding TNGST provisions. Its compostable bags were made from Poly Lactic Acid (PLA) and Poly Butylene Adipate Terephthalate (PBAT), tested by CIPET under IS/ISO 17088 and certified by the Central Pollution Control Board (CPCB) for manufacture of compostable carry bags. The applicant stated that, from 22.09.2025, Notification No. 9/2025-CT(R) dated 17.09.2025 reduced GST to 5% for specified paper sacks/bags and bio-degradable bags under Entry 319 of Schedule I, and sought a ruling on classification and eligibility for the concessional rate.

The applicant argued that compostable plastics constituted a specialised subset of biodegradable plastics, that its products satisfied IS/ISO 17088 standards, and that its certification and biodegradability supported classification as biodegradable bags eligible for the 5% rate. During the personal hearing on 06.07.2026, the authorised representative also relied on a Ministry of Environment, Forest and Climate Change press release dated 23.03.2026 concerning GST rationalisation and green transition. Further submissions dated 13.07.2026 stated that the applicant’s PLA-PBAT products were starch-based and covered by the rationale described in the press release. Physical samples were also produced before the Authority.

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Author Info

CA Sandeep Kanoi
Qualification: CA in Job / Business
Company: Taxguru Consultancy
Location: Mumbai, Maharashtra
Articles Published: 19,668

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