2018 (7) TMI 74 - AAR - GST

Classification of manufactured goods - brackets and clamps of cast iron - The applicant is of the view that though the products manufactured by it are used by building construction industry in hanging wash basin, commodes and urinals etc., the said products manufactured by it are required to be classified under Chapter Heading 7325 or 7308 or 7326 of the HSN - Whether the article manufactured by the applicant fall under Chapter Heading 7308, 7325 or 7326 of the HSN or any other heading? - Held that - The applicant manufactures cast articles, does sand blasting on the CI Casting for cleaning purpose and applies enamel so that the article does not get rusted. The articles manufactured by the applicant are not machined. Chapter Heading 7325 covers all cast articles of iron or steel, not elsewhere specified or included - the brackets and clamps of cast iron manufactured by the applicant are product of casting industry, inasmuch as on the rough CI Casting of the said product, the applicant does sand blasting and apply enamel to protect the product from rusting. The brackets and clamps so manufactured are not machined by the applicant therefore the same cannot be termed to have acquired the essential character as parts of sanitary ware - the articles (brackets and clamps) manufactured by the applicant fall under Chapter Heading 7325. Ruling - The articles (brackets and clamps) manufactured by the applicant fall under Chapter Heading 7325.

Summary

Issues Involved:
Classification of goods - Brackets and clamps of cast iron under Chapter Heading 7308, 7325, or 7326 of the HSN.

Analysis:
The applicant, a manufacturer of CI Casting, sought clarification on the classification of their products under Chapter Heading 7308, 7325, or 7326 of the HSN. The applicant's manufacturing process involves melting pig iron and scrap in a cupola furnace, adding foundry minerals, and pouring the melted iron into sand moulds to create cast articles used in various industries. Additionally, they manufacture brackets and clamps of cast iron for building construction industry use. The applicant argued that their products should be classified under specific chapters of the HSN based on Circulars and previous rulings.

The applicant highlighted that their products are cast articles not machined, undergo sandblasting and enamel application for protection against rust. The Central Goods & Services Tax and Central Excise Commissionerate, Ahmedabad North opined that the brackets and clamps of cast iron are classifiable under Chapter sub-heading 7325 99 10 of the GST tariff. The Authority considered these submissions along with the applicant's arguments and the Commissionerate's views.

Upon examination, the Authority referred to Chapter Note 1 of Chapter 73 of the Customs Tariff Act, which defines "cast iron" and Chapter Heading 7325 covering "Other cast articles of iron or steel." It was noted that the brackets and clamps of cast iron manufactured by the applicant, being products of casting industry not machined by them, are appropriately classified under Chapter Heading 7325. Therefore, the ruling concluded that the articles (brackets and clamps) manufactured by the applicant fall under Chapter Heading 7325.

In conclusion, the Authority ruled that the articles (brackets and clamps) manufactured by M/s. Alka Industries are correctly classified under Chapter Heading 7325 of the HSN.