In re Radha Paper Agencies (GST AAR West Bangal)
Summary: The West Bengal Authority for Advance Ruling considered an application filed by Radha Paper Agencies, a trader dealing in various types of paper falling under Chapter 48 of the Customs Tariff, including uncoated paper classifiable under HSN 4802. The application arose following amendments introduced by Notification No. 10/2025-Central Tax (Rate) dated 17.09.2025. The applicant sought clarification on whether uncoated paper supplied to manufacturers for exclusive use in making exercise books, graph books, laboratory notebooks and notebooks qualified for exemption, whether the supplier was required to verify end use, whether purchaser declarations or additional documents were necessary, whether classification depended solely on actual use, whether the supplier could be liable for subsequent misuse or misclassification, and whether any ambiguity existed around the rate-transition date.
The Authority examined Section 97(2) of the CGST Act, 2017 concerning the matters for which an advance ruling may be sought. It held that questions A, D and F fell within the statutory scope because they concerned determination of tax liability and applicability of the notification. Questions B, C and E, dealing principally with verification of end use, supporting declarations or certificates and supplier liability for subsequent purchaser conduct, were held to fall outside the scope of the relevant notification and were therefore not admitted.
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