Bulk Purified Water via Tankers Exempt from GST | AAR

Case Details: Hisham Transport, In re [2025] 176 taxmann.com 723 (AAR - KERALA)

Judiciary and Counsel Details

• Jomy Jacob and Mansur, Member
• M.A. Moideen, Chartered Accountant for the Appearing Parties.

The applicant, engaged in the supply of drinking water, sought a ruling on the taxability of water supplied in bulk through tanker lorries after undergoing basic purification. The applicant submitted that water was collected from various sources and subjected to filtration and chlorination before supply. It was contended that the water was not supplied in sealed containers, nor did it undergo processes similar to those used in the production of aerated, mineral, distilled, medicinal, ionic, battery or de-mineralised water. The supply was made to various customers, including Government institutions, and the applicant claimed exemption under Sl. No. 99 of Notification No. 02/2017-Central Tax (Rate), dated 28-06-2017. The matter was accordingly placed before the Authority for Advance Ruling (AAR), Kerala.

AAR Held

The AAR held that the applicant’s supply involved only basic purification processes, namely filtration and chlorination, which are commonly used to make water potable and do not align with methods employed in the manufacture of specified water types excluded under Sl. No. 99. It further observed that the water was supplied in bulk through tankers and not in sealed containers. Accordingly, the AAR ruled that the supply of drinking water in bulk to customers through tanker lorries falls within the scope of the exemption under Sl. No. 99 of Notification No. 02/2017-Central Tax (Rate), dated 28-06-2017.

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