TMI Blog2021 (1) TMI 428X X X X Extracts X X X X X X X X Extracts X X X X ..... different sub-headings, viz. Slide Fasteners under chapter sub-heading 9607.11/9607.19 and Parts thereof under chapter sub-heading 9607.20. Further under GST, the rate of tax is also separately prescribed for Slide Fasteners and Parts thereof. Hence, it is necessary to decide first whether these products are Slide Fasteners or Parts of slide fasteners . It is found that the product, Finished Zipper is supplied in cut length with sliders attached. The product Finished Zipper consists of two narrow strips of textile material. One edge of each strip is fitted with scoops of base metal (of metal, plastics etc.), which can be made to interlock by means of slider or runner. Thus, this a complete product, which can be construed as Slide Fasteners - further, it is noted that the product Zip Roll is supplied in continues length as per customer order or of normal length as per industrial specification. Zip Rolls are narrow strips of any length mounted with chain scoops and same are supplied without sliders/runners attached. Hence, this product falls under Parts of slide fasteners and cannot be classified as Slide Fasteners , as claimed by the applicant - slider shall be ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ,- (vii) after S. No. 231A and the entries relating thereto, the following serial number and the entries shall be inserted, namely:- 231 B 9607 Slide Fasteners (C) in Schedule III- 9%,- (xvi) in S. No. 446, for entries in column (2) and (3), the following entries shall be substituted, namely:- 9607 20 00 Parts of slide fasteners 2.2 Thus, prior to 27.07.2018, Slide Fasteners and its Parts were levied single rate of 18%. However, from 27.07.2018, Slide Fasteners are levied to total tax (CGST +SGST) @ 12% and Parts of Slide Fasteners are levied to total tax (CGST +SGST) @ 18%. 3. In view of above backdrops, the applicant sought Advance Ruling on: Classification as per HSN and rate of tax in terms of the Notification No.01/2017-Central Tax (Rate) dated 28.06.2017 as amended by the Notification No.18/2018-Central Tax (Rate) dated 26.07.2018 in respect of their products, (i) The Zip Roll (i.e. Slide Fasteners), (ii) Finished Zippers and (iii) Sliders. The products (scan copies) are shown in Annexure A attached and samples ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... 18% in terms of S. No. 446 of Notification No.01/2017- Central Tax (Rate) dated 28.06.2017 as amended by Notification No.18/2018- Central Tax (Rate) dated 26.07.20178. Scan images of said products as shown in annexure-A by the applicant are reproduced herein below: 4.4 The above said information has been brought to the notice of the authority, in view of the changes made applicable in the rate of duty by Notification No.18/2018- Central Tax (Rate) dated 26.07.2018 to Slide Fasteners and its Parts under two different rates of 12% and 18% w.e.f. 27.07.2018. 5. At the time of personal hearing held through Video Conferencing on 18.06.2020, the Authorised Representative of the applicant, Shri Bhaveen Shah reiterated the facts as stated in the Application. DISCUSSION FINDINGS: 6. We have considered the submissions made by the applicant in their application for advance ruling as well as at the time of personal hearing. We also considered the question/issue on which advance rulings have been sought for by the applicant, relevant facts having bearing on the questions/ issues raised and the applicant s understanding/interpretation of law in respect of the issu ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... whether these products are Slide Fasteners or Parts of slide fasteners . 10.1 For the ease of reference, relevant entries of HSN are reproduced herein below: As per HSN: 9607 SLIDE FASTENERS AND ITS PARTS THEREOF - SLIDE FASTENERS 9607.11- Fitted with chain scoops of base metal 9607.19-Others 9607.20- Parts This heading covers: (1) Slide Fasteners of any size and for any purpose (for clothing, footwear, travel goods etc.). Most Slide Fasteners consist of two narrow strips of textile material. One edge of each strip being fitted scoops of base metal (of metal, plastics etc.) which can be made to interlock by means of slider or runner. Another type of Slide Fasteners consists of two strips of plastics, each with a specially edge designed to interlock one with other under the action of a Slider. (2) Parts of slide fasteners e.g. chain scoop, sliders, or runners, end pieces and narrow strips of any length mounted with chain scoops. 10.2 On perusal of the scan images of the products and Explanatory Notes to the HSN, we find that the product, Finished Zipper is supplied in cut length with sliders attached. The product Fini ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... 9% Thus, till 26.07.2018, Slide Fasteners and its Parts were levied GST at single rate of 18%. II. During the period from 27.07.2018 to 30.09.2019: 11.2 Further, vide Notification No.18/2018-Central Tax (Rate) dated 26.07.2018, the following amendments were made in the Notification No.1/2017-Central Tax dated 28.06.2017: (B) in Schedule II- 6%,- (vii) after S. No. 231A and the entries relating thereto, the following serial number and the entries shall be inserted, namely:- 231 B 9607 Slide Fasteners (C) in Schedule III- 9%,- (xvi) in S. No. 446, for entries in column (2) and (3), the following entries shall be substituted, namely:- 9607 20 00 Parts of slide fasteners From the above, it appears that w.e.f. 27.07.2018, Slide Fasteners and Parts of slide fasteners were levied GST at two different rates viz. Slide Fasteners are levied GST @ 12% (CGST +SGST) and whereas Parts of slide fasteners are levied GST @ 18% (CGST +SGST). III. From 01.10.2019 to till date: 11.3 Further, vide Notific ..... X X X X Extracts X X X X X X X X Extracts X X X X
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