The Ruling stated that Quick Lime and Hydrated Lime with purity below 98% fall under HSN 2522 as industrial lime, not high-purity chemical compounds under HSN 2825. Accordingly, GST at 5% applied instead of the higher 18% rate.

The Tribunal observed that revenue has compared the figures reflected in the ST-3 returns and figures reflected in Form 26AS statement and raised the demand without further examining the reasons for the difference in the two statements.