End-use exemption for uncoated paper requires actual qualifying use; purchaser declarations alone cannot establish entitlement.

End-use exemption for uncoated paper requires actual qualifying use; purchaser declarations alone cannot establish entitlement.Case-LawsGSTEntry No. 128 exempts uncoated paper and paperboard under Heading 4802 only when actually used to manufacture exe…

End-use exemption for uncoated paper requires actual qualifying use; purchaser declarations alone cannot establish entitlement.
Case-Laws
GST
Entry No. 128 exempts uncoated paper and paperboard under Heading 4802 only when actually used to manufacture exercise books, graph books, laboratory notebooks or notebooks. Tariff classification alone does not establish eligibility: the use-based condition requires a factual end-use relationship, and purchaser declarations, purchase orders or contractual terms evidencing intended use are not conclusive. Exemption notifications require strict construction and cannot be expanded through unstated certification or verification requirements. As no statutory framework prescribes end-use certificates, bonds, monitoring, diversion consequences or records, the Advance Ruling Authority cannot recognise purchaser documents as a legally sufficient compliance mechanism. The manner of availing the exemption falls outside advance-ruling jurisdiction.
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