In re Kayeee Industrial Chemicals Private Limited (GST AAR Tamilnadu)
The applicant, a registered GST assessee engaged in the manufacture of Quick Lime and Hydrated Lime, imports high-purity limestone from Oman through importers and agents. The limestone is calcined in a lime kiln to obtain Quick Lime (CaO) with a purity of about 90%. This Quick Lime is then sprayed with water to produce Hydrated Lime (Ca(OH)₂), which has a purity ranging from 85% to 95%. The applicant filed an Advance Ruling application to clarify whether Quick Lime and Hydrated Lime with purity below 98% attract GST at 5% or 18%. They stated that they have been collecting GST at 5% when purity is below 98% and that the products fall under Tariff Heading 2522.
The application fee was duly paid, and the State authorities confirmed that there were no pending adjudication proceedings. The Authority observed that the questions raised fall under Section 97(2)(a) and (c) of the CGST Act, 2017, and accordingly admitted the application. In the personal hearing held on 23.09.2025, the authorised representatives reiterated their submissions, producing supply orders from the Kerala Water Authority, invoices, and relevant Indian Standard specifications for Hydrated Lime. They informed that they charged 5% GST for Hydrated Lime with purity up to 86% and 18% if purity exceeded 86%. Their customers had sought clarity due to a clarification from the Rajasthan State GST authority indicating that Hydrated Lime with up to 98% purity attracted 5% GST.
