Agricultural Seedling Trays of Plastic classifiable under CTH 39269099

In re M/s. Saro Enterprises (GST AAAR Tamilnadu) In the case at hand, the product, ‘Agricultural Seedling Tray’, is made up of Plastics and not of any of the base metals specified in the section notes as stated by the Appellant themselves. The contention of the Appellant is that the trays are used for germination of paddy and therefore, the product is to be considered as a ‘Hand tool used for agriculture’ and classified under 8201. We find that Chapter 82 covers only those tools made of base metals; The construction of description 8201 is a typical one attracting the ap...