The Gujarat Authority for Advance Ruling (AAR) in the case of Manishaben Vipulbhai Sorathiya (Trade name: Autotech) vide Advance Ruling No. GUJ/GAAR/R/2023/10 dated 09.03.2023, has ruled that GST at the rate of 28% is payable on the supply of floor mats made up of PVC leather mixed with other substances for four wheelers motor vehicles (cars).

In this case, the applicant is in the business of manufacturing and supplying floor mats for four-wheel motor vehicles (cars). The floor mats are essentially made poly vinyl chloride (PVC) material.

The applicant sought an advance ruling in respect of the appropriate classification and rate of GST applicable to the supply of PVC floor mats (cars) under CGST and SGST.

The Applicant submitted that the product would be taxable at 18 per cent GST since it is an admixture of PVC leather, PU foam and XLPE foam, bound together by using a cotton thread and adhesive, consequent to which a heel pad is affixed. Accordingly, the product should be classified either under the heading 3918 (floor coverings of plastic) or 3904 (PVC not mixed with any other substance), which draw 18 per cent GST. For this, the applicant relied on the Haryana AAR given in the case of M/s. Stinzo Automotive (P) Ltd., where it was ruled that the PVC floor mats, used for motor vehicles, would fall within the ambit of CTH 390410.

The AAR noted that Custom Tariff Heading (CTH) 3904 clearly provides that it covers PVC items not mixed with any other substance. However, this is not being the case in the goods manufactured by the applicant, and therefore the question of the PVC mat of the applicant falling within the ambit of 390410 does not arise. Further, for the goods to fall within the ambit of 390 I to 3914, they have to be in primary form. The goods in relation to waste, parts, and scrap, as well as semi-manufactured items and articles, would appropriately have to be classified from CTH 3915 onward. Also, the product does not fall under 3918 as it covers within its ambit floor wall and ceiling coverings of plastics.

The AAR ruled that the product comes under 8708, which covers parts and accessories of motor vehicles subject to certain conditions. This classification draws a GST of 28 per cent.