In re Cummins Technologies India Private limited (GST AAR Maharashtra)
Maharashtra Authority for Advance Rulings (AAR) has held that the After Treatment System (ATS), a critical component for controlling vehicle emissions, is classifiable as a part of a motor vehicle under Chapter Heading 8708 of the Goods and Services Tax (GST) tariff. The authority rejected the applicant’s plea to classify the product under Chapter Heading 8421, which covers general-purpose filtering and purifying machinery. The ruling, delivered on April 30, 2025, hinges on a detailed analysis of the product’s design, use, and its inability to function independently of the vehicle it is made for.
The applicant, Cummins Technologies India Private Limited, is a manufacturer of exhaust after-treatment systems and other components for medium-duty, heavy-duty, and high-horsepower engines. The ATS, also known as an Exhaust Gas Processor (EGP), is a mandatory fitment in vehicles to comply with the Bharat Stage VI (BS-VI) emission standards prescribed by the Ministry of Road Transport and Highways.
The system’s primary function is to filter and purify harmful engine exhaust gases like Carbon Monoxide (CO) and Nitrogen Oxides (NOx), converting them into less harmful substances such as Carbon Dioxide (), Nitrogen (), and water. It comprises several key components, including a Diesel Oxidized Catalyst (DOC), Diesel Particulate Filter (DPF), Selective Catalytic Reduction (SCR) Catalyst, and an Ammonia Slip Catalyst (ASC), all working in concert to treat the exhaust.
Cummins Technologies contended that since the ATS is fundamentally an apparatus for filtering and purifying gases, it should be classified under Tariff Heading 8421, which pertains to “Centrifuges, including centrifugal dryers; filtering or purifying machinery and apparatus, for liquids or gases.”
