2026-VIL-154-AAR
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SGST Advance Ruling Authority

GST – Tamil Nadu AAR - Appropriate classification and applicable GST rate for aerator gear boxes and spare parts used in aquaculture for prawn rearing - under chapter 8436 as agricultural machinery or under chapter 84834000 - Applicant manufactures and supplies aerator gear boxes and spare parts previously classified under HSN 84834000 attracting GST rate of 18 percent - Following GST 2.0 reforms under Notification 9/2025-Central Tax (Rate) dated 17.09.2025, Applicant proposed reclassification under HSN 84368090 as other agricultural machinery to qualify for concessional GST rate of 5 percent - Whether aerator gear boxes and spare parts used in aquaculture for prawn rearing merit classification under HSN 8436 (Other agricultural, horticultural, forestry, poultry-keeping or bee-keeping machinery) qualifying for 5 percent GST rate - HELD - Aerator gear boxes do not merit classification under HSN 8436 as there is specific entry 84834000 describing gears, gear boxes and speed changers, and when specific entry describing goods exists, that subheading is the correct classification - Applicant is not manufacturer of agricultural machinery but only supplies gear boxes as component parts fitted into aerator machinery used in aquaculture, which does not merit classification under chapter 8436 covering only agricultural, horticultural, forestry, poultry-keeping or bee-keeping machinery - Spare parts when supplied separately including toothed wheels and transmission elements merit classification under HSN 84839000 - Aerator gear boxes attract GST rate of 18 percent under HSN 84834000 and spare parts attract GST rate of 18 percent under HSN 84839000 - Ordered accordingly
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