AAR: Paddle Wheel Aerators for Aquaculture Attract 18% GST, Not 5%:

AAR: Paddle Wheel Aerators for Aquaculture Attract 18% GST, Not 5% M/s Bindhu Industries, Bhimavaram, manufactures and supplies Paddle Wheel Aerators used exclusively in aquaculture ponds to enhance dissolved oxygen levels through water agitation. The aerators comprise components such as floats, impellers, frames, shafts, motors and gearboxes. The applicant had been classifying the product under HSN 8479 89 99 and paying GST at 18%. After Notification No. 9/2025-Central Tax (Rate), which reduced GST to 5% on aerators essential for aquaculture, the applicant sought clarification on whether the product should fall under HSN 8436 80 90 at 5%, and whether its parts would qualify under HSN 8436 99 90 at the concessional rate. Issue Before AAR: Whether Paddle Wheel Aerators used in aquaculture ponds are classifiable under HSN 8436 attracting 5% GST Rate or under HSN 8479 attracting 18%, and whether their parts qualify for the concessional rate. AAR's Decision: The Authority for Advance Ruling held that Paddle Wheel Aerators are correctly classifiable under HSN 8479 89 99 as “machines and mechanical appliances having individual functions, not specified elsewhere in Chapter 84.” The Authority observed that Notification No. 9/2025–Central Tax (Rate) did not amend the HSN classification or mandate reclassification under HSN 8436. It further noted that HSN 8436 mainly covers agricultural and allied machinery generally associated with land-based farming operations, whereas paddle wheel aerators are specialised mechanical devices designed for water circulation and oxygenation in aquaculture ponds. In the absence of a specific entry under HSN 8436, the residual heading 8479 continues to apply. Therefore, GST at 18% remains applicable to Paddle Wheel Aerators. The Authority also held that their components, such as float assemblies, impellers, frames, power train and protective covers, are classifiable under HSN 8479 90 90 and attract GST at 18%, and do not qualify under HSN 8436 99 90. To Read Full Judgment, Download PDF Given Below