2026-VIL-144-AAR
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SGST Advance Ruling Authority

GST – West Bengal AAR - Classification of uncoated paper classifiable under HSN 4802 – End-use based exemption – The applicant procures paper intended for manufacture of exercise books from paper mills and supplies the same to registered manufacturers engaged in manufacture of exercise books, graph books and educational notebooks. Applicant procures paper for non-educational use at 18 percent GST rate. Prior to amendment, all supplies of uncoated paper under HSN 4802 attracted uniform GST rate of 12% regardless of end use. Amendment introduced by Notification No. 10/2025-Central Tax dated 17.09.2025 provides exemption where paper is used for exercise books, graph books, laboratory notebooks and notebooks, while same HSN attracts 18% GST for other uses - Whether supply of uncoated paper falling under HSN 4802 to manufacturer for exclusive use in manufacture of exercise books qualifies for exemption under Notification No. 10/2025 – HELD – The rate classification of uncoated paper and paperboard under tariff heading 4802 for GST purposes is solely based on actual use of paper. The phrase "used for" in the notification is of utmost importance indicating that there is no scope for intention of use but actual use of goods is required. Classification is unambiguous and based solely on usage - The notification contemplates two kinds of use of uncoated paper and paperboard namely uncoated paper used for exercise books, graph books, laboratory notebooks and notebooks and uncoated paper used for other purposes. Where manufacturer uses uncoated paper exclusively for production of exercise books the goods qualify for Sl. No. 128 and supply to said manufacturer will be exempt from GST on condition that referred paper and paperboard has been used for manufacturing of exercise book, graph book, laboratory notebook and notebooks - If the same goods under tariff heading 4802 are used for purposes other than manufacturing of exercise books, graph books, laboratory notebooks, and notebooks, it will be covered by entry no. 167 of Schedule II of Notification No. 09/2025-CT (Rate) dated 17.09.2025 and will be taxed 18% GST - Regarding transition period, notifications became effective from 22.09.2025 and there is no ambiguity regarding effective date - Ordered accordingly
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