A detailed analysis of the Kerala AAR ruling on GST classification and tax rate for Rooter Trainer Cups used in rubber plant propagation by Oruma Plastics.
Saloni Kumari | Jul 8, 2025 |
GST Rate of 18% Applicable on Agricultural Implement Used Exclusively for Propagation of Plants: AAR
M/S. Oruma Plastics Private Limited is the legal applicant in this case. The applicant is a company registered with the address 14/420F, Kinfra F block, Chapparapadavu, Kannur, Kerala-670581. M/s. Oruma Plastics Pvt Ltd is a taxpayer registered under the CGST/KSGST Act, involved in the manufacturing of “Rooter Trainer Cups.” The cup is mainly used for growing rubber plants, which is part of agricultural activity. The company is now asking the Kerala Authority for Advance Ruling (AAR) to clarify how this product, i.e., the Rooter Trainer Cup, should be classified under GST, and if yes, then what tax rate applies.
The company said that its product is used only for farming purposes, specifically for rubber plant nurseries. They also got a certificate from the Rubber Research Institute of India, which confirmed that this cup is important for rubber plant propagation and is recommended for agricultural use. The company pointed out that the cups are used by farmers and nurseries and are made from plastic. They even referred to a past AAR decision where plastic cups used for collecting rubber latex were treated as agricultural tools.
The company wants its product to be treated as a tax-exempt agricultural implement. They suggested that it should fall under HSN code 8201 9000, which covers hand tools used in agriculture and are exempt from GST.
The applicant, M/S. Oruma Plastics Private Limited has asked the following question before the Kerala Authority for Advance Ruling, Goods and Services Tax Department, Tax Tower, Thiruvananthapuram, seeking the advance ruling No. KER/10/2025. Dated 16.04.2025:
“Question: 1. Classification and rate of agricultural implements, namely the Rooter Trainer Cup, made of plastic, used exclusively for propagation of plants, an agricultural activity.”
In accordance with the Kerala Authority for Advance Ruling Goods and Services Tax Department, Tax Tower, Thiruvananthapuram, the following answer has been given to the above question:
Answer: Rooter Trainer Cups with sizes of 600 cc and 800 cc, manufactured from plastic and used for the propagation of rubber plants, are classified under HSN 3926 90 99 with the product description “other articles of plastic.” The product is classifiable under HSN 3926 90 99 with the description “Other articles of plastic” and is taxable at 9% under Sl. No. 111 of Schedule III of Notification No. 1/2017-Central Tax (Rate) dated 28.06.2017 (as amended) and at 9% under the corresponding SGST notification, making the effective GST rate 18%.
When the tax authority checked the laws and GST rules, the tax authority discovered that the HSN code suggested by the company (8201 90 00) doesn’t fit because that category is only for tools made of metal. Since the Rooter Trainer Cup is made of plastic, it can’t be included under that section.
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