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Case Law Details

Case Name : In re Saddles International Automotive & Aviation Interiors Private Limited (GST AAAR Andhra Pradesh)
Appeal Number : Advance Ruling No. Order /AAAR/AP/03(GST)/2024
Date of Judgement/Order : 26/04/2024
Related Assessment Year :
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In re Saddles International Automotive & Aviation Interiors Private Limited (GST AAAR Andhra Pradesh)

In the case of Saddles International Automotive & Aviation Interiors Private Limited before the GST Appellate Authority for Advance Ruling (AAAR) in Andhra Pradesh, the primary issue was the classification of seat covers for motor vehicles. The appellant contended that these seat covers should be classified under Chapter 9401, which pertains to “seats for motor vehicles.” However, the AAAR found that these seat covers are more accurately classified under heading 8708, which covers parts and accessories for motor vehicles.

The AAAR observed that the seat covers produced by the appellant are designed to fit over existing seats in motor vehicles. Their primary function is to provide protection and enhance comfort, distinguishing them clearly from the actual seats themselves. The distinction is crucial because heading 9401 specifically pertains to “seats for motor vehicles,” not accessories or additional coverings for those seats. The appellant’s product, being a seat cover, does not fall under this category but rather under heading 8708, which addresses parts and accessories of motor vehicles.

The discussion also highlighted the distinction between “parts” and “accessories” as defined in the GST regime and the pre-GST period. Historically, seat covers were classified as “accessories” under heading 8708 according to Circular No. 541/37/2000-Central Excise from 2000. This classification was supported by past tribunal judgments, including the case of Guru Overseas Pvt. Ltd. Vs. CCE, Delhi, where car seat covers were deemed accessories under Chapter 8708. The AAAR reaffirmed this classification, noting that the nature of seat covers as accessories remains consistent across tax regimes.

Further, the AAAR examined the definition of “accessory” from the Oxford English Dictionary, which describes it as an additional or supplementary item that contributes to the main item—in this case, the seat covers add to the functionality and style of vehicle seats but are not integral parts of the seats themselves. This interpretation aligns with the classification under heading 8708, which encompasses accessories used specifically with motor vehicles.

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