Pooja Panneer / Pooja Rosewater attracts 18% GST, Not Exempt as Puja Samagri: AAR [Read Order]
Rosewater is not used exclusively for religious purposes, as it is widely used for room freshening, linen sprays, and spa treatments. Therefore, end-use arguments cannot override established GST classification principles.
The Tamil Nadu Authority for Advance Ruling (AAR) has held that “Pooja Panneer” or “Pooja Rose Water” sold for religious and ritual purposes is not eligible for GST exemption available to “puja samagri” and is liable to GST ( Goods and Services Tax ) at the rate of 18%.
M/s T.S.R. & Co., a Tamil Nadu-based manufacturer of “Pooja Panneer” (Rose Water), which is marketed and sold for use in Hindu, Jain, Sikh and other Indian religious rituals such as abhishekam, deity cleansing, sprinkling, consecration and aarti welcome ceremonies. They filed an application seeking the HSN code of the same.
The applicant submitted that the product consists of deionized or RO water mixed with rose distillate, hydrosol or rose essence and is sold in small retail packs bearing labels such as “For Puja Use Only” and “Not for Cosmetic Use.”
It contended that the product is supplied mainly through pooja stores, temple counters and devotional marketplaces and is not marketed as a cosmetic, toilet water or room freshener.
The applicant further argued that rose water used for rituals is functionally equivalent to holy water and should therefore qualify for GST exemption available to puja samagri. They also cited entry No. 167 of Notification No. 10/2025-Central Tax (Rate), which grants exemption to specified puja samagri items.
The Authority clarified that the exemption notification for religious goods is exhaustive, as indicated by the word "namely." Because the list specifically identifies items like rudraksha, panchamrit, and chandan tika, but omits rose water (panneer), the product cannot be exempted as puja samagri.
The AAR ruled that the applicant's product cannot be classified as "rose water" under tariff item 3303 00 20. It noted that the product is not used exclusively for religious purposes, as it is widely used for room freshening, linen sprays, and spa treatments. Therefore, end-use arguments cannot override established GST classification principles.
After the lab reports, instead, the bench of B. Susheel Kumar and C. Thiyagarajan held that the product was more appropriately classifiable under HSN 3301 90 79 as “aqueous solutions of essential oils – others.” Goods falling under Heading 3301 are subject to GST at the rate of 18%, comprising 9% CGST and 9% SGST.
Therefore, the Tamil Nadu AAR ruled that “Pooja Panneer” or “Pooja Rose Water” does not qualify as exempt puja samagri under GST. The product is classifiable under HSN 3301 90 79 and attracts GST at the rate of 18%.
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