In re Nagarjuna Agro Chemicals Private Limited (GST AAAR Telangana)
(i) The Refill Reagents, said to be chemicals/chemical substances, however, as supplied to the customers, have no identity whatsoever by any specific name, description or contents etc., so as to show their actual nature / composition. Their only identity is in terms of the SI. No.s assigned i.e, Reagent No. 1 to Reagent No. 42; and as mentioned above, the Mridaparikshak Minilab Operations Manual specifies their usage by a reference to these assigned SI.No.s. only.
(ii) Thus, the Refill Reagents have the only identity as items/accessories to be used with the Mridaparikshak instrument / Minilab and none else; for the customers/recipients who use them. Evidently, in the absence of the actual name/composition etc. , the Refill Reagents cannot be put to any other use.
(iii) Note 2 to Chapter 90 specifies criteria, under three clauses (a) to (c), for classification of parts and accessories of the instruments/apparatus falling under the Chapter. Clause (a) is not applicable to Refill reagents, since these are not goods which by description / nature etc., fall under Chapters 84, 85, 90 or 91. Clause (b) speaks of parts and accessories, suitable for use solely or principally with a particular kind of machine.
