In re Link Up Textiles Private Limited (GST AAAR Tamilnadu)
The present appeal was filed under Section 100(1) of the Central Goods and Services Tax Act, 2017 and the Tamil Nadu Goods and Services Tax Act, 2017 against an advance ruling dated 08.10.2025 issued by the Tamil Nadu State Authority for Advance Ruling. The appellant, a private limited company registered under GST, is engaged in exporting men’s pyjama sets comprising a top (kurta/shirt) and bottom (pyjama/trouser) made of cotton, polyester, and spandex blends, packed as two sets per pack. The appellant had initially sought an advance ruling on the appropriate HSN classification and applicable GST rate for such products when sold in combined packs.
The Authority for Advance Ruling had ruled that when two pyjama sets are packed together and priced below ₹1,000 per piece or set, the applicable GST rate would be 5% under the relevant notification. Aggrieved by this decision in respect of cases where the value per set exceeds ₹1,000, the appellant preferred an appeal contending that the correct unit for taxation should be a “set” and that a GST rate of 12% should apply where the value per set exceeds ₹1,000, in terms of the relevant schedule.
