2026-VIL-05-AAR
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SGST Advance Ruling Authority

GST – West Bengal AAR - Classification of supply of CKD e-rickshaw and the applicable GST rate - To optimize logistics and facilitate sales through authorized dealers/assemblers, the applicant intends to supply electric three-wheeler passenger and goods transport vehicles (e-rickshaws) in a Completely Knocked Down (CKD) condition - Whether the supply of a complete set of components of an electric three-wheeler vehicle (e-rickshaw) in a Completely Knocked Down (CKD) form, necessary and sufficient for the assembly of the finished vehicle, should be classified as (a) the finished vehicle itself or (b) a set of parts – HELD - The Rule 2(a) of the General Rules for the Interpretation of the Harmonized System (GIR) and the Office Order issued by the Commissioner of Customs, ICD, TKD, New Delhi, identified five essential components of an e-rickshaw. The presence of the motor and any three of the other four essential components satisfies the "essential character" test under Rule 2(a) for classifying the CKD supply as the finished vehicle - If the CKD parts contain the motor and any three of the four essential components (transmissions, axles, chassis and controller) in proportionate numbers capable of building complete e-rickshaws, then the supply should be classified as the finished vehicle itself and be taxed at 5% GST under HSN code 87038040 and serial no. 441 of Schedule I of the GST notification - However, if the supply does not include either the motor or any two of the other four essential components, then it should be classified as a set of parts and taxed at 18% GST under the respective HSN codes for the individual parts – Ordered accordingly
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