PVC Raincoats Being Non-Woven Products to Be Classified Under HSN 392620 and Attract GST Rate of 18% | AAR

Case Details: Aristocrat Industries (P.) Ltd., In re - [2025] 173 taxmann.com 371 (AAR-WEST BENGAL)

Judiciary and Counsel Details

• Dr. Tanisha Dutta & Joyjit Banik, Member
• Vikash Dhanania, C.A Sumit Jaiwal, A/R, for the Petitioner.

Facts of the Case

The applicant, engaged in the manufacture of raincoats primarily composed of polyvinyl chloride (PVC), filed an application before the West Bengal Authority for Advance Ruling under Section 97 of the West Bengal Goods and Services Tax Act, 2017. The applicant sought a ruling on whether such raincoats should be classified under HSN 3926 20 as plastic articles or under HSN 6201 40 10 as textile garments. The applicant stated that the raincoats, though composed of PVC, are used as apparel and hence there was ambiguity regarding appropriate classification under the GST regime.

AAR Held

The Hon’ble West Bengal Authority for Advance Ruling held that PVC raincoats are non-woven products, and PVC sheets used in their manufacture cannot be regarded as woven fabric. It further observed that, in common parlance, PVC sheets are not treated as textile materials. Since the raincoats are primarily composed of polyvinyl chloride (PVC), they do not qualify for classification under textile headings. Accordingly, the AAR ruled that such raincoats are classifiable under HSN 3926 20 as articles of apparel and clothing accessories. It concluded that the supply of PVC raincoats attracts GST at the rate of 18%, in terms of Entry No. 111 of Schedule III of Notification No. 1/2017-Central Tax (Rate), dated 28-06-2017, read with corresponding West Bengal Notification No. 1125-F.T., dated 28-06-2017.

List of Cases Referred to

• Saurashtra Chemicals v. Collector of Customs, Bombay 1985 taxmann.com 200/[1986] 23 ELT 283 (CEGAT- NEW DELHI) (para 2.7)
• Porritts & Spencer (Asia) Ltd. v. State of Haryana 1978 taxmann.com 13/[1983] 13 ELT 1607 (SC) (para 2.12)
• CCE v. MRF Ltd. 1997 taxmann.com 225/[1998] 97 ELT 23 (SC) (para 2.12)
• CCE v. India Waterproofing & Dyeing Works 1996 taxmann.com 5/87 ELT 340 (SC) (para 2.12).