In re Aristocrat Industries Private Limited (GST AAR West Bangal)
Authority for Advance Ruling (AAR) in West Bengal addressed the classification of PVC raincoats manufactured by Aristocrat Industries Pvt. Ltd. under the Goods and Services Tax (GST) regime. The applicant sought clarification on whether these raincoats, primarily composed of polyvinyl chloride (PVC), should be categorized under HSN Code 3926 (plastic articles) or HSN Code 6201 (textile articles). Additionally, the applicant inquired about the applicable GST rate, particularly if items priced below ₹1,000 would attract a 5% GST rate.
The applicant argued that the manufacturing process of PVC raincoats involves fusion methods, avoiding traditional stitching to maintain waterproof integrity. They cited the Customs Authority for Advance Rulings (CAAR) decision in NZ Seasonal Wear Pvt. Ltd., which classified similar PVC raincoats under HSN Code 6201 as articles of apparel. Chapter Notes of the Customs Tariff Act, 1975, were emphasized, indicating that non-woven articles of man-made fibers, such as PVC raincoats, should be classified under Chapter 62 if they serve as apparel.
In its analysis, the AAR relied on CGST Notification 01/2017 and the General Rules of Interpretation of the Customs Tariff Act. Chapter Heading 6201, which encompasses overcoats, raincoats, and similar garments made from various materials, was deemed most appropriate. Specifically, sub-heading 62014010 covers garments made from man-made fibers. The AAR underscored that the classification aligns with the product’s use as a protective garment and its material composition, making HSN Code 6201 suitable.
