In re Myvision Medical Private Limited (GST AAR Gujarat)
Summary: The Gujarat Authority for Advance Ruling (AAR), in the case of My Vision Medical Private Limited, examined the classification and applicable GST rate on specialised ophthalmic medical furniture and equipment manufactured by the applicant. The company manufactures motorised surgeon’s chairs, doctor’s sitting stools, ophthalmic refraction chair units, eye operating tables, ophthalmic instrument trolleys and ophthalmic instrument tables. These products are specifically designed for ophthalmic examinations, refraction testing, diagnostic procedures and eye surgeries. The applicant sought clarification on whether these products should be classified under HSN 9018 as medical or surgical instruments attracting 5% GST or under HSN 9402 as medical, surgical or similar furniture attracting 18% GST.
The applicant submitted that its products were not ordinary furniture but specialised medical equipment incorporating motorised controls, precision adjustment mechanisms, electrically operated components and medical-grade construction. It argued that the products were exclusively intended for use in hospitals, ophthalmic surgical centres, diagnostic eye clinics and optical examination rooms. According to the applicant, their principal function was to facilitate ophthalmic diagnosis, examination and surgical procedures rather than provide conventional seating or furniture utility. Accordingly, the applicant proposed classification under HSN 9018, which covers instruments and appliances used in medical, surgical, dental or veterinary sciences.
The Authority examined the descriptions, photographs and technical characteristics of the products, along with the relevant provisions of the Customs Tariff Act, 1975, Chapter Notes and Harmonised System explanatory notes. It observed that Heading 9018 covers medical and surgical instruments and appliances, whereas Heading 9402 specifically includes medical, surgical, dental and veterinary furniture, such as operating tables, examination tables and specialised chairs. The Authority noted that the mere incorporation of electrical controls, motorised movements, adjustable mechanisms and specialised medical features does not automatically convert an article of furniture into a medical or surgical instrument.
The Authority further observed that the principal characteristics of the applicant’s products remained those of specialised medical furniture. Motorised surgeon’s chairs and doctor’s sitting stools primarily provide seating and positioning facilities for medical practitioners, while ophthalmic refraction chair units facilitate the positioning of patients during eye examinations. Similarly, eye operating tables provide adjustable support for patients during surgical procedures, and ophthalmic instrument tables and trolleys support and accommodate diagnostic or surgical equipment. Although these products are specifically designed for ophthalmic applications, their essential nature and intended functions bring them within the description of medical and surgical furniture under Heading 9402.
After considering the relevant tariff provisions and HSN explanatory notes, the Authority concluded that the applicant’s motorised surgeon’s chairs, doctor’s sitting stools and ophthalmic refraction chair units are appropriately classifiable under tariff heading 94021090. The eye operating tables, ophthalmic instrument trolleys and ophthalmic instrument tables are classifiable under tariff heading 94029090. The Authority therefore rejected the applicant’s proposed classification under HSN 9018 and held that the specialised nature and medical application of the products did not alter their classification as furniture under Chapter 94 of the Customs Tariff.
Regarding the applicable GST rate, the Authority referred to Entry No. 611 of Schedule II to Notification No. 09/2025-Central Tax (Rate), dated 17 September 2025. It held that all the products covered by the application attract GST at 18%, comprising 9% CGST and 9% SGST. Consequently, the applicant’s claim for classification under HSN 9018 at 5% GST was not accepted. The ruling establishes that ophthalmic products principally functioning as specialised medical furniture are classifiable under HSN 9402, notwithstanding their exclusive use in medical examinations, diagnostic procedures or surgical operations.
