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No Ruling in Absence of Complete Documentation for GST Classification: AAR Gujarat

Case Law Details

TaxGuru Citation
2025 taxguru.in 2476
Case Name
In re Vegan Wood Pvt Ltd. (GST AAR Gujarat)
Date of Judgement/Order
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In re Vegan Wood Pvt Ltd. (GST AAR Gujarat)

M/s. Vegan Wood Pvt Ltd., a manufacturer of ‘Natural Fibre Composite Board’ (NFC) in Gujarat, sought an advance ruling regarding the GST classification of their ‘rice husk board.’ The company produces these boards by pulverizing rice husk, mixing it with lime powder, processing additives, and PVC resin, then extruding the compound into boards of varying thicknesses. They argued that because rice husk, a natural fiber, is the dominant raw material, the product should be classified as wood and articles of wood under Chapter 44, specifically CTH 441193, attracting a 12% GST rate.

The Gujarat Authority for Advance Ruling (AAR) reviewed the applicant’s manufacturing process and material composition. The AAR referenced research from the Indian Plywood Industries Research Institute (IPIRI) and Bureau of Indian Standards (BIS) specifications for particle boards, highlighting the use of ligno-cellulosic materials, including rice husk, in their production. However, the AAR noted significant deficiencies in the applicant’s submission. The provided test report, though from a NABL accredited laboratory, had a disclaimer stating that not all parameters were within their accreditation scope and lacked reference to relevant BIS standards. Additionally, the AAR pointed out the applicant’s failure to provide supporting documents like brochures, purchase invoices, and sales invoices. Furthermore, the AAR found a striking resemblance between the applicant’s submission and a previous ruling, raising concerns about the submission’s authenticity.

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Author Info

CA Sandeep Kanoi
Qualification: CA in Job / Business
Company: Taxguru Consultancy
Location: Mumbai, Maharashtra
Articles Published: 19,987

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