2026-VIL-176-AAR
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SGST Advance Ruling Authority

GST - Classification of electric three-wheeler (e-rickshaw) supplied in Completely Knocked Down (CKD) form - Applicant, a manufacturer of battery-operated e-rickshaws, proposed to supply the vehicle to its authorised dealers in unassembled condition for assembly at the dealer's premises, as a single kit under a single invoice, composite price and consignment - Whether the supply of a complete set of components of an e-rickshaw in CKD form, necessary and sufficient for assembly of the finished vehicle, should be classified as the finished vehicle itself or as a set of parts, and the applicable rate of GST - HELD - An e-rickshaw is covered by HSN 87038040 and is taxable at 5% GST under serial no. 441 of Schedule I of Notification No. 11/2017-Central Tax (Rate), as amended - Following the order of the Appellate Authority in M/s Navya Electric Vehicle case, which applied Rule 2(a) of the General Rules for Interpretation, the proposed CKD supply satisfies all four cumulative conditions laid down by the WBAAAR - The proposed kit, supported by a proforma invoice and packing list, supplied under a single invoice, single composite price, single e-way bill and single packing list, with orders and warranty in terms of vehicles and each vehicle carrying a chassis number, satisfies the first three conditions, while the fourth is to be examined in situ at the time of supply - When all four conditions are fulfilled, the supply is a finished e-rickshaw in CKD form taxable at 5% GST on the total composite value, and failure to satisfy any one condition results in classification as individual parts and components taxed at the rate applicable to them – Ordered accordingly
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