Rajasthan AAR Classifies Rubberised Cork Sheets Under HSN 45041010 at 5% GST

In re Balasaria Agencies Pvt. Ltd. (GST AAR Rajasthan)

Summary: The Rajasthan Authority for Advance Ruling considered the classification and GST rate of rubberised and agglomerated cork sheets supplied by Balasaria Agencies Pvt. Ltd., trading as Pristine Technologies & Industries. The applicant described its goods as industrial sheets made by mixing cork granules with polymer or rubber, chemicals and curatives, processing oil and fillers, then moulding, curing and cutting the material. Its declared composition comprised 30.99% cork and 42.47% polymer. It sought classification under tariff item 4504 10 10 and the 5% rate under serial number 310 of Schedule I to Notification No. 09/2025-Central Tax (Rate) dated 17 September 2025. It also asked whether the presence of rubber, the absence of natural cork in the finished sheet, or the origin of cork could defeat that entry, and whether it could claim an inverted duty refund. The jurisdictional officer argued that polymer predominated and that the goods should fall in Chapter 40 at 18%.

The Authority admitted the four classification and rate questions. It found no pending classification proceeding that would bar the application: the applicant reported only a verbal doubt raised during refund scrutiny, and the officer confirmed that no proceeding was pending. It declined to admit the fifth question because refund entitlement is outside the matters listed in Section 97(2). On classification, the Authority applied the express terms of heading 4504, which cover agglomerated cork with or without a binding substance and impose no quantitative limit or restriction on the binder. It treated the polymer system as the binder holding agglomerated cork granules together, rather than treating cork as a filler in a rubber compound. The separate entries for natural cork and agglomerated cork also defeated the proposed natural-cork restriction. The Authority held that the sheets fall under tariff item 4504 10 10 and serial number 310, attracting 2.5% central and 2.5% State tax on supplies made on or after 22 September 2025. It gave no ruling on refund eligibility.