In re Luxor International Private Limited (GST AAR Uttarakhand)
The Authority for Advance Ruling, Uttarakhand considered an application under Section 97(1) of the CGST Act, 2017 and the corresponding UKGST Act filed by M/s Luxor International Private Limited concerning the GST treatment of uncoated paper classified under HSN 48025590. The applicant manufactures and supplies stationery, notebooks and exercise books and proposed to supply uncoated paper exclusively for manufacturing notebooks and exercise books. It sought a ruling on whether such paper qualified for exemption under Entry No. 128 of Notification No. 10/2025-Central Tax (Rate) dated 17.09.2025 and was therefore not liable to CGST at 9%, instead of the 18% GST rate under Notification No. 09/2025-Central Tax (Rate) dated 17.09.2025. The applicant relied on the use-based distinction between the two notifications and proposed obtaining purchase orders and end-use declarations from buyers. It also submitted after the personal hearing that manufacturers would provide post-production declarations correlating the supplied paper with production batches and quantities used for notebooks and exercise books. The concerned Deputy Commissioner (State Tax) submitted that exemption could not be granted merely on the basis of purchaser declarations and that the notification did not prescribe an end-use verification mechanism. The personal hearing was conducted virtually on 22.07.2026, followed by additional submissions from the applicant on 23.07.2026.
