The Gujarat Authority for Advance Ruling has held that HDPE Geomembrane manufactured by weaving HDPE tapes (less than 5 mm width) and laminating with LDPE/LLDPE for waterproof pond lining in aquaculture and agriculture is classifiable under sub-heading 59111000 of the Customs Tariff Act as a textile product for technical use, and was taxable at 12% GST under Entry 168 of Schedule II of Notification No. 01/2017-CT (Rate) up to 21.09.2025, and stands reduced to 5% GST under Entry 386 of Schedule I of Notification No. 09/2025-CT (Rate) effective 22.09.2025 under GST 2.0. The ruling by Members Vishal Malani and Sushma Vora in GUJ/GAAR/R/2026/37 (M/s Shree Salasar Balaji Polysack Pvt. Ltd., decided 29.09.2026) follows the Gujarat HC’s judgment in Anantha Synthetic Innovations and the AAR’s own earlier rulings in Texel Industries and EMMBI Industries (Daman AAR).
The AAR held that HDPE strips of less than 5 mm width are synthetic textile materials under Tariff Heading 5404 per Section Note 1(g) to Section XI, and woven fabrics from such strips fall under Heading 5407. Chapter Note 8(a)(i) to Chapter 59 covers textile fabrics coated with ‘other material’ for technical purposes — and the HSN Explanatory Notes confirm that ‘other material’ includes plastic. The geomembrane’s use in Biofloc aquaculture technology (doubling stocking density, insulating animals from diseases) satisfies the ‘technical use’ requirement. The AAR also noted that Note 7 referenced in the rate notification entries was renumbered as Note 8 by the Finance Act, 2021.
- 2026-juristway.com-2785-AAR(Gujarat)-GST | AAR Gujarat | GUJ/GAAR/R/2026/37 | 29.09.2026
