2025 (3) TMI 312 - AAAR - GST

Appropriate classification rate of GST applicable on supply of PVC floor mats Cars under CGST and GGST - HELD THAT - The PVC floor mats for use in cars supplied by the applicant is classifiable under CTH 8708 would be leviable to GST @ 28%. Appeal dismissed.

Summary

The issues presented and considered in the legal judgment are as follows:1. Classification and rate of GST applicable on the supply of PVC floor mats for cars under the CGST and GGST Acts.2. Appropriate classification of the PVC floor mats under the Central Goods and Services Tax Act, 2017 and the Gujarat Goods and Services Tax Act, 2017.3. Interpretation of the relevant provisions of the Acts in determining the classification of the PVC floor mats.The detailed analysis of the identified issues is as follows:The Appellate Authority for Advance Ruling considered the appellant's contentions regarding the classification and rate of GST applicable to PVC floor mats for cars. The appellant argued that the floor mats should be classified under CTH 3918 as floor coverings of plastic. However, the GAAR found that the PVC floor mats should be classified under CTH 8708 as parts and accessories of motor vehicles. The GAAR's reasoning was based on the specific provisions of the Acts and the nature of the product in question.Key evidence and findings presented included the composition of the PVC floor mats, the manufacturing process involved, and the relevant HSN classifications for the raw materials used in the mats. The GAAR considered the constituent materials of the mats, their intended use, and the specific provisions of the Acts in reaching its decision.The GAAR interpreted the provisions of the CGST Act, 2017 and the GGST Act, 2017 in light of the appellant's arguments and the specific details of the case. The GAAR reasoned that the PVC floor mats, being tailor-made for motor vehicles and falling under the category of parts and accessories of motor vehicles, should be classified under CTH 8708.Competing arguments were presented by the appellant regarding the classification of the PVC floor mats under different headings, such as CTH 3918 and CTH 5705. The appellant also relied on the case of Uni Products India Ltd. to support their classification argument. However, the GAAR found that the appellant's arguments were not tenable based on the specific facts and provisions applicable to the case.The significant holdings of the judgment include:- The PVC floor mats for cars are classifiable under CTH 8708 and are subject to a GST rate of 28%.- The appellant's appeal against the Advance Ruling was rejected based on the classification determined by the GAAR.In conclusion, the judgment upheld the GAAR's classification of the PVC floor mats under CTH 8708 and rejected the appellant's arguments for alternative classifications. The decision was based on a thorough analysis of the relevant legal framework, precedents, evidence, and the application of the law to the facts of the case.