In recent order Authority for Advance Ruling(AAR), Tamil Nadu ruled that supply of LED stem (long bulb) that is outdoor lighting fixtures with LED integrated inside them is taxable at the rate of 6% CGST and with 6% SGST.
The Applicant, lnventaa LED Lights Private Limited is engaged in the design, manufacture, and supply of LED Lights of various applications in a wide range of sizes and voltage with fixtures and fittings where the fixtures and fittings are made up of Plastic, Aluminium, Steel or a combination thereof. The applicant has stated that they have developed a LED Stem (Long bulb) which has a 360-degree light output and at the same time saves power up to 60% in comparison to the CFL bulb, whereas the conventional LED bulb delivers only 180-degree light output.
The applicant had applied for an Advance Ruling seeking the classification and the rate for the products dealt by them. However as they were informed that the question has to specifically state the models, they were seeking an advance ruling in respect of Category A products – LED stem Long bulb used in LED Garden Lights, LED Outdoor Lights, and LED Bollard Series.
The issue concerning was whether the supply of full product of the LED stem with fixtures or fittings is single or composite or mixed supply and the applicable GST Tariff code and rate.
The Coram consisting of Ms. Manasa Gangotri Kata (Member, CGST) and Mr. Kurinji Selvaan V.S (Member, TNGST) applied the explanation (iii) and (iv) to Notification No. 1/2017 – Central Tax (Rate) Dt. 28-06-2017, tariff heading, sub-heading, heading and chapter shall mean respectively a tariff item, sub-heading, heading and chapter as specified in the First Schedule to the Customs Tariff Act, 1975 and the rules for the interpretation of the First Schedule to the Customs Tariff Act, 1975, including the Section and Chapter Notes and the General Explanatory Notes of the First Schedule for interpretation and classification of goods.
From further interpretation, the bench found it evident that Chapter 94 falls under Section XX which covers `Miscellaneous Manufactured Articles’. They said that;
“Lamps and light fittings can be of any source and made of any material. Further, those lamps and light fittings covered under Chapter 85 are not covered under this heading by the specific exclusion in the Chapter Notes. Further, lamps for exterior lighting are covered under CTI-I 9405. In the instant case, the product is a LED lamp fixture with LED light integrated into it which can function independently as garden lights. Therefore, they are classifiable under CTH 94054090 as ‘other electric lamps and light fitting’.”
The bench further determined the GST rate of the LED lights or fixtures including LED lamps at 6% CGST and 6% SGST.