2018 (9) TMI 1105 – AUTHORITY FOR ADVANCE RULING, MAHARASHTRA – 2018 (17) G. S. T. L. 659 (A. A. R. – GST) – Classification of goods – marine paints – Whether marine paints supplied by the applicant, would be considered to be part of ship and accordingly be then classified under SI no 252 of Schedule I of Notification No 1/2017 of Central Tax (Rates) dated June 28, 2017?
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Held that:- here is no dispute with regard to classification of the subject goods under CTH 3208 and 3209. The difference of opinion is only with respect to the claim of the applicant that the goods are parts of ship and therefore would be eligible for concessional rate of IGST @ 5% as given under Sr. No. 252 of Schedule -I of Notification No. 1/2017 of Integrated Tax (Rates).
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The benefit of concessional rate of IGST @5% is available to parts of goods of headings 8901, 8902, 8904,8905,8906 and 8907 – it is very apparent that parts of goods of Heading 8901, 8902, 8904, 8905, 8906 and 8907 are eligible for
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tial parts or equipments of a vessel/ship.
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The items that are discussed as essential parts of a ship/ vessel are such essential components of a vessel/ ship without which the ship would not be complete and would not exist. These are very integral for the functioning of the ship and can be separated from the ship for repair/replacement. There are various consumable items like paints varnish, oils, grease, etc. which are essentially applied and used in or on all or most of these essential ship parts as discussed above to make them tenable, durable and worthy of the ocean. Once applied, these consumable items are consumed and lost and cannot be reused and are also not worth recovery, reuse or recycle for use on ship.
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Considering the meaning of an expression (Part) as defined in the dictionary, besides common parlance test it can be safely concluded that Marine Paint is not a component part of Ship. This conclusion which we have drawn as above gets support from the facts stated
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dvance ruling in respect of the following issues. 1. Whether marine paints supplied by the applicant, would be considered to be part of ship and accordingly be then classified under SI no 252 of Schedule I of Notification No 1/2017 of Central Tax (Rates) dated June 28, 2017? At the outset, we would like to make it clear that the provisions of both the CGST Act and the MGST Act are the same except for certain provisions. Therefore, unless a mention is specifically made to such dissimilar provisions, a reference to the CGST Act would also mean a reference to the same provision under the MGST Act. Further to the earlier, henceforth for the purposes of this Advance Ruling, a reference to such a similar provision under the CGST Act / MGST Act would be mentioned as being under the GST Act . 02. FATC AND CONTENTION – AS PER THE APPLICANT The submission (Brief facts of the case), as reproduced verbatim, could be seen thus – Jotun Group is a leading supplier of paints and powder coatings. The A
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d Service Tax Legislation (SGST) Integrated Goods and Service Tax Act, 2017 (IGST) With the introduction of GST, Applicant has analysed classification and applicability of CGST, SGST and IGST in light of new legislation. For classification, it has been clarified in the rate notification of respective legislation that rule for interpretation Of the First Schedule to the Customs Tariff Act, 1975 including Section notes and Chapter notes and general explanatory notes of the said First Schedule would be applicable for the purpose of classification under GST. Accordingly, Applicant has sought to classify paints being supplied under HSN 3208 and 3209 on the basis of nature of the product and after considering relevant chapter notes and section notes. Notification No 1/2017 – Integrated Tax (Rate) dated June 28, 2017 prescribes applicable rate of IGST (hereinafter referred to as IGST Rate Notification). Paint supplied by Applicant are classifiable under Chapter Heading 3208 and 3209 are cover
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bmits that marine paint is a specific type of paints suitable for use principally for ships during building stage and even during maintenance. The sailing ship needs protection from corrosive environment in which they operate. Such marine corrosion has a significant impact on sea carriers and their longevity. Therefore, effective corrosion control strategies are chosen considering appropriate selection of coating for a marine environment. Marine coatings have special functionality to protect marine vessels and other carriers above and below the waterline. Accordingly, marine paints supplied by Applicant has following technical features: Protects the body Of Ship from highly corrosive environment Blocks barnacles and other marine organisms from adhering to the hulls of ships Lessens fuel consumption as it controls damage to the ship. Prevents impact on water eco-systems by reducing emission of Green House Gases. Transportation of marine organisms to other areas Vide notification no 1/20
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o this Chapter Thus based on the technical specification of the product, marine paints appear to be classifiable under heading 3208. Since, marine paint is suitable for use for Ships, it could also get classified as part of Ship. For the purpose of this analysis, Applicant referred to chapter 89 for 'Ships, boats and floating structure'. However, Applicant wishes to draw your attention to the fact that there is no specific entry in Chapter 89 for 'parts' of ships covered therein. In the absence of any entry for part of ship, Applicant had adopted classification of marine paint under chapter heading 3208. Applicant has also been adopting similar classification under Central Excise Law. The excise duty liability has accordingly been discharged by Applicant in erstwhile Indirect Tax regime, Sample copy of invoice which was issued under erstwhile regime, has been enclosed as annexure 5 for your ready reference. CLASSIFICATION UNDER GST A3. Basis the IGST Rate notification,
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ted June 28, 2017 liable to 5% IGST: Sr.No. Chapter/Heading/ Sub-heading/ Tariff item Description of Goods 252. Any Chapter Parts of goods of heading 8901, 8902, 8904, 8905, 8906 and 8907' Description of goods falling under above referred heading, are mentioned below: Sr.No. Chapter/Heading/ Sub-heading/ Tariff item Description of Goods 246 8901 Cruise ships, excursion boats, ferry-boats, cargo ships, barges and similar vessels for the transport of persons or goods 247 8902 Fishing vessels; factory ships and other vessels for processing or preserving fishery products 248 8904 Tugs and pusher craft 249 8905 Light-vessels, fire-floats, dredgers, floating cranes and other vessels the navigability of which is subsidiary to their main function; floating docks; floating or submersible drilling or production platforms 250 8906 Other vessels, including warships and lifeboats other than rowing boats 251 8907 Other floating structures (for example, rafts, tanks, coffer-dams, landing-stages,
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ication No. 6/2002 exempts parts, falling under any Chapter used within factory of production for manufacture of goods of Heading 8701, the benefit cannot be denied to the product which not fall under said chapter. The goods falling under any Chapter, as long as they are parts of goods of Heading 87.01 will be covered by the said Notification. A7. Thus bearing in mind, entry 252 of Schedule I of GST classification notification (1/2017 – Integrated Tax dated June 28, 2017) and aforesaid case law, one may interpret that goods falling under any chapter, as far as they constitute to be part of vessel/ship, would be subjected to tax at 5%. A8. Accordingly, for marine paints to be classified under this entry, it should be construed as 'part of the ship' covered under entry 252. B. Marine paint is mandatorily to be applied on all ships under Merchant Shipping Act, 1958 and hence the same should be considered as part of Ship B1. As highlighted above, there is no separate tariff item as
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the above, it could be understood that anything which is an integral element and is also essential to an object, could be considered as part of that article. Anything required to make the goods a finished item can be described as component parts. Applicant hereby submits relevant provisions of Merchant Shipping Act, 1958 ('MS Act' for brevity) which would help in demonstrating that marine paint is integral and essential component of ship. Section 356P(1) of MS Act: Application of chapter XIB-Control Of Harmful Anti-Fouling Systems On Ships Save as otherwise provided in this Part, this Part shall apply to- a. every Indian ship, wherever it is; b. ships not entitled to fly the flag of India, but which operate under the authority of India; and c. Slaps that enter a port, shipyard, or offshore terminal or place in India or within the territorial waters of India or any marine areas adjacent thereto over which India has, or may hereafter have, exclusive jurisdiction in regard to con
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on 356X of MS Act – Information regarding contravention of the provisions of Convention 1. If, on receipt of a report from a surveyor or other person authorised to inspect a ship, the Director-General is satisfied that any provision of this Part has been contravened by such ship within the coastal waters, the Director-General or any officer authorised by him in this behalf, may- a. detain the ship until the causes of such contravention are removed to the satisfaction of the Director-General or the officer authorised by him; and b. levy penalty on such ship as specified in section 436 B4. From conjoint reading of the above provisions, it is evident that every ship has to adhere to the anti-fouling provisions as prescribed under MS Act. Basis the Same, a layer of coating or paint, has to be applied on the hull of the ship to control or prevent attachment of unwanted organisms. Further in the Concise Oxford English Dictionary, the term hull is defined as follows- The main body of a ship o
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'parts', it is relevant to refer to legal jurisprudence available in this regard wherein meaning of 'parts' has been deliberated. C2. The Hon'ble Supreme Court, in case of Star Paper Mills Ltd. Vs. Collector of Central Excise, Meerut [1990] 76 STC 312 (SC), = 1989 (8) TMI 78 – SUPREME COURT OF INDIA has ruled that if it is found that the use of paper core is necessary in any/process incidental or ancillary to the completion of paper as marketable goods it would consequently be commercially inexpedient to sell paper without the use of paper core, it would certainly be a constituent part of paper and would thus fall within the purview of the term component parts used in the notification. C3. The Hon'ble Gujarat High Court, in case of Surgichem Vs. State of Gujarat [1992] 87 STC 40 (Guj) = 1991 (7) TMI 303 – GUJARAT HIGH COURT observed that it is clear that anything that goes into the product till the product becomes marketable, such thing becomes part and parcel o
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end product. C5. From the above, it could be summarized that paper core, plastic spools and wrapping paper would be considered to be parts of paper rolls, adhesive plaster tapes and paper reams/reels respectively since without the former goods, the later goods couldn't be marketed or are commercially inexpedient. Thus an analogy could be drawn that anything which is required for making goods marketed or to be marketable, would be form component part of that end products. C6. Basis the provisions of The Merchant Shipping Act, ships are bound to adhere to the 'anti-fouling system' norms. Accordingly, ship would not be marketable unless the same has complied with anti-fouling system i.e. application of paints/coating to avoid growth of unwanted organisms. C7. Thus applying the ratio derived from aforementioned legal jurisprudence in the current situation, a view can be taken that since the ship is not commercially expedient without following anti-fouling system, paints would
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AHMEDABAD stated that following: he has also submitted a list of goods in respect of which exemption has been allowed to manufacturers supplying the goods to National Aerospace Laboratories, HAL etc. as detailed below : 9.1 Aircraft cables (manufacturer – Radiant Cables Pvt. Ltd.) 9.2 Paints (manufacturer – South Field Paints & Chemicals Pvt. Ltd.) 9.3 Expoxi Yellow Primer (manufacturer – South Field Paints & Chemicals Pvt. Ltd.) 9.4 Thinner for yellow primer (manufacturer – South Field Paints & Chemicals Pvt. Ltd.) 9.5 Rivets (manufacturer – M/s. Ankit Forgings) 9.6 Epoxi black paint (manufacturer – South Field Paints & Chemicals Pvt. Ltd.) 9.7 Industrial Laminates Fabric (manufacturer – Lamtuf Plastics Ltd.) D2. From the facts of above case, it could be understood that paints when supplied to manufacturers of aircrafts /helicopter, are treated as parts of aircraft and thus would be eligible for claiming benefit of nil rated duty under notification 6/2002-Central Excis
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er Raw materials and parts NIL 2 and 3* *Condition 2 – Where such use is elsewhere than in the factory of production, the exemption shall be allowed if the procedure laid down in the Central Excise (Removal of Goods at Concessional Rate of Duty for Manufacture of Excisable Goods) Rules, 2001, is followed. Condition 3- The exemption shall be allowed if it has been proved to the satisfaction of an officer not below the rank of the Deputy Commissioner of Central Excise or the Assistant Commissioner of Central Excise, as the case may be, having jurisdiction that such goods are cleared for the intended use. E3. Vide above mentioned entry, rate of excise duty for raw material and parts, for use in the manufacture of different types of vessels has been prescribed as nil. Accordingly, goods falling under any chapter meant for use in the manufacture of vessel was made liable to nil rate of duty. E4. Thus, it can be inferred that intention of the legislators is to grant benefits to all the produ
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f United Kingdom also considers paint as part of ship F1. Value Added Tax (VAT) was introduced in the UK on April 1, 1973. Although Value Added Tax Act 1994 (VATA) provides the lain framework of the tax, the detailed interpretation of the same are found in statutory instruments either in the form of Orders made by Treasury or Regulations made by Her Majesty's Revenue and Customs (HMRC). HMRC has published several Notices and Leaflets affecting law. Though these Notices are not part of the law but they explain how HMRC interprets the law. F2. Applicant would also like to draw your attention to the VAT provisions laid in United Kingdom as regards parts or components of ship. Following is the extract of such germane provisions: a. Section 30(2) of Value Added Tax Act 1994 A supply of goods or services is zero-rated by virtue of this subsection if the goods or services are a description for the time being specified in Schedule 8 or the supply is of a description for the time being so s
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ertainment equipment crockery and cutlery raw materials such as: fibre board, plastics, and specialist metals bulk materials such as: adhesives, chemicals, fabrics, inhibitors, metals, oils, paints, solvents and thinners etc aircraft ground equipment flight simulators or their parts, and tooling and equipment used for manufacturing parts or equipment F3. Now as per section 30(2) of VATA, any supply of goods or services would be zero-rated if the supply of goods are covered under Schedule 8 of the Act or supply of goods to the person to whom he supplies services is covered under the description provided. Further Schedule 8 of the Act includes supply of parts and equipment, of a kind ordinarily installed or incorporated in, and to be installed, or incorporated in the propulsion, navigation, communication systems or the general structure of a qualifying ship. F4. Thus as per section 30(2) read along with Schedule 8 of VATA, supply of parts and equipment of installed or incorporated in the
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Since entry at Sr no 252 has been newly introduced under GST Tax Schedules, inference could be drawn from Customs Tariff Act. Hence the meaning of the term 'parts of goods of heading 8901, 8902, 8904, 8905, 8906 and 8907' has to be adopted in general parlance. 3. Thus we have referred to definitions of 'Part' in various Dictionaries. Accordingly, part of an article is an integral part necessary to the constitution of the whole article and without it, the article will not be complete. 4. Further as per MS Act, anti-fouling system has to be mandatorily followed by every Ship since non-adherence of the same would be liable to severe penal actions. Therefore paints form an essential part of the ship without which ship couldn't be marketed. 5. Furthermore applying the analogy drawn from the germane legal jurisprudence it is said that anything which is required for making goods marketed or to be marketable, would be form component part of that end products and hence pain
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ions The dealer has requested in Annexure 1 that a ruling be pronounced under section 97(2) a of the CGST Act 2017 on the following questions:- a) Whether marine paints supplied by the applicant, would be considered to be part of ship and accordingly be then classified under Sl. no.252 of Schedule I of Notification No. 1/2017 of Central Tax (Rates) dated June 28, 2017? The dealer is dealing in marine paint. In GST there is separate entry of paints but the dealer is requesting to classify these paints as part of ship. Men there is a specific entry for any commodity the said commodity cannot be classified in another way. Therefore the dealer's request cannot be accepted. 04. HEARING The case was taken up for preliminary hearing on dt. 20.032018, with respect to admission or rejection of the application when Sh. Nitin S Shah, Advocate, duly authorized, appeared and made oral submissions for admission of application as per details in their written submissions. During hearing, the juris
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d coatings that are designed for unique conditions. In the subject case they have made submissions with respect to paints supplied to the shipping industry. They have stated that the paints supplied by them in the subject case are classifiable under Chapter Heading 3208 and 3209 which are covered under Schedule IV of Notification No. 1/2017-lntegrated Tax (Rate) dated 28.06.2017 and are accordingly liable to 28% IGST. However further to their claim that their goods 'Marine paints' are classifiable under CTH 3208 and 3209 and individually as per tariff are liable to IGST @ 28%, but the applicant is claiming that in the present facts of the case wherein they are supplying their goods marine paints for use on ships and therefore their goods would get covered under Sr. No.252 of Schedule -I of Notification 1/2017 of Integrated Tax (Rates) dated 28.06.2017 and would be liable to IGST @ 5% as they are parts of goods of Headings 8901, 8902, 8904, 8905, 8906 and 8907. Further we find t
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olymers or chemically modified natural polymers, dispersed or dissolved in a non-aqueous medium; solutions as defined in Note 4 to this Chapter. CTH 3209:- Paints and varnishes (including enamels and lacquers) based on synthetic polymers or chemically modified natural polymers, dispersed or dissolved in an aqueous medium. We find that in normal parlance, 'paint' means any liquid or composition that, after application to a substrate in a thin layer, converts to a solid film. It is most commonly used to protect, color, or provide texture to objects. There are various types of paints like enamel paint, emulsion pain, lacquer paint, varnish paint (without pigment), etc. One of the type of paint is 'Anti-fouling' paints. Anti-fouling paints are generally paints that are applied to hulls of ships. They prevent barnacles and other marine organisms from adhering to the hulls of ships. Thus it is the contention of the applicant that such types of paints sold by them should be tr
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port of persons or goods 247 8902 Fishing vessels; factory ships and other vessels for processing or preserving fishery products 248 8904 Tugs and pusher craft 249 8905 Light-vessels, fire-floats, dredgers, floating cranes and other vessels the navigability of which is subsidiary to their main function; floating docks; floating or submersible drilling or production platforms 250 8906 Other vessels, including warships and lifeboats other than rowing boats 251 8907 Other floating structures (for example, rafts, tanks, coffer- dams, landing-stages, buoys and beacons) Now when we know as to what are the goods covered under above CTH, we are required to examine and see if marine paints are parts of goods of the above referred CTHs. First of all we need to examine as to what are Parts . We find that the word Part/Parts has not been defined in GST nor was it defined in Central Excise earlier. In view of this first we are required to understand the general meaning of the word 'Part/ Parts&
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ne as to what are the parts of Goods of CTH 8901, 8902, and 8907 and whether marine paints can be taken to be covered within the meaning of Parts for Sr. No. 252 of Notification no. 1/2017-integrated Tax, We find that Anchor, Bow, Bowsprit, Fore and Aft, Hull, Keel, Mast, Rigging, Rudder, Sails, Shrouds, Engines, gearbox, Propeller, Bridge, etc. are the very essential parts of a ship or vessel and are quite clearly parts of a vessel/ ship and a ship cannot be imagined to be in existence without these parts. However, in addition to the above there are some additional equipments that are required to be made available on a ship as a measure of statutory compliances under various marine acts such as Merchant Shipping Act or Additional Safety measures such as Walkie-talkie, Binoculars, Life Jackets, Lifeboats, etc. Though these are also to be compulsorily made available on a vessel and ship but cannot be taken to be parts of a ship as per general understanding but are rather additional equi
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ems are consumed and lost and cannot be reused and are also not worth recovery, reuse or recycle for use on ship. The main function of marine paints as per applicant's submissions is … Protection the body of ship from highly corrosive environment Blocking barnacles and other marine organisms from adhering to the hulls of ships Lessening fuel consumption as it controls damage to the ship. Preventing impact on water eco-systems by reducing emission of Green House Gases. Preventing Transportation of marine organisms to other areas. When we refer to the definition of the word 'part' as discussed in detail above, we find that 'part' is a separate piece of something or a piece that combines with other pieces to form the whole of something. In this regard we find that marine paints are in no way piece of ship that would in any way form the whole ship. They are just consumables for the essential parts of ship. Similarly the second definition of part also defines '
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cation inserted following entry for prescribing effective rate of excise for goods mentioned therein. Sr. No. Chapter or heading or sub-heading or tariff item of the First Schedule Description of excisable goods Rate Condition No. 306C Any chapter Raw materials and parts NIL 2 and 3* *Condition 2 – Where such use is elsewhere than in the factory of production, the exemption shall be allowed if the procedure laid down in the Central Excise (Removal of Goods at Concessional Rate of Duty for Manufacture of Excisable Goods) Rules, 2001, is followed. Condition 3 – The exemption Shall be allowed if it has been proved to the satisfaction of an officer not below the rank of the Deputy Commissioner of Central Excise or the Assistant Commissioner of Central Excise, as the case may be, having jurisdiction that such goods are cleared for the intended use. In fact the said notification gave exemption to all raw materials and parts for use in the manufacture of certain specified ships/vessels, subje
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ithout which, final product cannot be conceived of. 13. The meaning of the expression component' in common parlance is that component part of an article is an integral part necessary to the constitution of the whole article and without it, the article will not be complete'. 14. This Court, in Star Paper Mills (supra) has made a settled distinction while considering whether paper cores are components' in the manufacture of paper rolls and manufacture of paper sheets. It is stated that paper cores' are component parts in so far as manufacture of roll is concerned, but it is not component part' in the manufacture of sheets. It is useful to quote the observations made by this Court :- "… paper core would also be constituent part of paper and would thus fall within the term "component parts" used in the Notification in so far as manufacture of paper in rolls is concerned. Paper core, however, cannot be said to be used in the manufacture of paper in sheet
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98 Tri Delhi, 1997 (94) ELT 234 Tri Del. = 1997 (5) TMI 152 – CEGAT, NEW DELHI the Two Member Bench of the Tribunal referred the appeal before the larger bench on the following questions: (i) Whether the phrase component parts occurring in Notification 77/90 would cover spare parts for the purpose of granting of benefit thereunder? The larger Bench of the Tribunal having regards to dictionary meaning of part , and Component observed that in common parlance meaning of the expression component is also the same, that is, one of the parts or elements of which anything is made up or into which it may be resolved or a Constituent. The meaning in common parlance has to be looked into since the notification itself does not contain any definition of the expression. In the State of Uttar Pradesh vs M/S. Kores (India) Ltd on 18 October, 1976, Equivalent citations: 1977 AIR 132, 1977 SCR (1) 837. = 1976 (10) TMI 131 – SUPREME COURT OF INDIA In this case the appellant contended before the Hon SC t
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clear of opinion that Carbon paper is not paper as envisaged by entry 2 of the aforesaid Notification. Regarding ribbon also to which the above mentioned rule construction equally applies, we have no manner of doubt that it an accessory and not a part of the typewriter (unlike spool) though it may not be possible to use the latter without the former. Just as aviation petrol is not a part of the aero- plane nor diesel is a part of a bus in the same way, ribbon is not a part of the typewriter though it may not be possible to type out any matter without it. The very same question with which we are here confronted came up for decision before the High Court of Mysore in State of Mysore v. Kores (India) Ltd. 26 STC 87). = 1970 (3) TMI 126 – MYSORE HIGH COURT (1) where it was held: Whether a typewriter ribbon is a part of a typewriter is to be considered in the light of what is meant by a typewriter in the commercial sense. Typewriters are being sold in the market without the typewriter ribb
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parts and equipment of a ship. However we find that the statutory provisions, conditions for benefit as given and referred by the applicant in UK VAT Act are in different context and therefore not relevant in the facts of the case in present matter. As per above detailed discussions we do not find any merit in the argument advanced by the applicant that Marine Paint should be considered as a part of Ship and accordingly find that marine paints are not covered under Serial No.252 of Schedule I of Notification No. 1/2017 of Central Tax(Rates) Dated June 28,2017. 06. In view of the extensive deliberations as held hereinabove, we pass an order as follows : ORDER (under section 98 of the Central Goods and Services Tax Act, 2017 and the Maharashtra Goods and Services Tax Act, 2017) NO.GST-ARA-29/2017-18/B-35 Mumbai, dt. 19/05/2018 For reasons as discussed in the body of the order, the questions are answered thus – Q1. Whether marine paints supplied by the applicant, would be considered to be
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