Geomembranes Classifiable as Textile Products, Not Plastics: AAAR [Read Order]

In a recent ruling, the Gujarat Appellate Authority for Advance Ruling (AAAR) has dismissed an appeal filed by the Deputy Commissioner, Central GST, and upheld the earlier ruling that manufactured geomembranes are classifiable as textile products for technical use under HSN 5911 10 00.

The dispute arose after the Department challenged the 2022 advance ruling in favour of the respondent Shree Ambica Geotex Pvt. Ltd., which treated geomembranes, HDPE‑based laminated fabrics used for waterproof pond linings, as textile articles.

The Department argued that the product should fall under HSN 3926 90 99 as plastic goods, citing earlier decisions including Raj Packwell Ltd. (MP High Court) and Gujarat Raffia Industries Ltd. (CESTAT Delhi).

During the hearing on January 21, 2026, departmental representative Shri Balchandra Pillai reiterated these precedents, while advocates Shri Amal Paresh Dave and Shri Parth P. Rachchh for the respondent relied on the Gujarat High Court’s judgments in Ananta Synthetic Innovations (2024 (89) GSTL 107 (Guj)) and CTM Technical Textiles Ltd. (2020 (12) TMI 1100 (Guj)), both of which held that woven HDPE fabrics laminated with plastic qualify as textiles under Chapter 59.

The appellate bench Arti Kanwar (SGST Member) and Sunil Kumar Mall (CGST Member) noted that the manufacturing process described by Shree Ambica Geotex mirrored that in Ananta Synthetic Innovations, where the High Court had conclusively ruled in favor of classification under Chapter 59.

The Authority observed that no special‑leave petition had been filed against that decision, rendering the issue settled law.

The bench rejected the department's reliance on Raj Packwell Ltd. and stated that the MP High Court case dealt with HDPE strips and sacks, not woven fabrics, and therefore could not override the Gujarat High Court’s interpretation that “woven fabric, irrespective of material, constitutes textile.”

Accordingly, the AAAR affirmed the earlier ruling GUJ/GAAR/R/2022/46 dated 18.10.2022, holding that geomembranes HDPE woven fabrics laminated with LDPE/LLDPE are textile articles for technical use under HSN 5911 10 00, and dismissed the Department’s appeal.

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