The Tamil Nadu Authority for Advance Ruling has held that aerator gear boxes and their spare parts used in aquaculture (prawn rearing) are not classifiable under HSN 8436 (Other agricultural/horticultural/poultry-keeping machinery) at 5% GST under Entry 434 of Schedule I of Notification No. 09/2025-CT (Rate) — the new GST 2.0 notification — and must continue to be classified under HSN 84834000 (Gear boxes and other speed changers) at 18% under Entry 468 of Schedule II. The ruling by Members R.V. Pradhamesh Bhanu and B. Suseel Kumar in TN/53/ARA/2026 (M/s BAS-J Industries, decided 18.08.2026) is among the first classification disputes arising from the GST 2.0 rate restructuring.
The applicant argued that since aerator gear boxes are used exclusively in aquaculture aerators for prawn rearing and cannot be used in other equipment, they should benefit from the concessional 5% rate extended to agricultural machinery under Entry 434. The AAR rejected this on two grounds: first, General Interpretative Rules require classification under the specific entry (HSN 84834000 for gear boxes) rather than a general entry (HSN 8436) when a specific entry exists; second, Entry 434 is confined to agricultural/horticultural/forestry/poultry-keeping/bee-keeping machinery — it does not extend to aquaculture/prawn rearing machinery, and no such entry exists in Schedule I. The AAR additionally corrected the applicant’s classification of spare parts (bevel pinions, gears, helical pinions, worm shafts) from HSN 84834000 to HSN 84839000 (toothed wheels and transmission elements presented separately), both attracting 18% GST.
- 2026-juristway.com-2529-AAR(Tamilnadu)-GST | AAR Tamil Nadu | TN/53/ARA/2026 | 18.08.2026