The Gujarat AAR has decided that an 18% GST is payable on dry citrate powder and bicarbonate bags. The bench of Sushma Vora and Vishal Malani has stated that the bag includes sodium bicarbonate, so it would merit classification under HSN 28363000.
At present, the applicant categorises the product as a medical device under HSN code 90189031, wherein the GST rate of 12% is applicable. The petitioner in his application has specified that at the time of the customs assessment, it was recommended that the specified product must be categorised as an organic chemical under chapter 29 with HSN code 29181590, making it obligated to pay GST at 18% rate.
The applicant sought an advance ruling on whether Dry Citrate Powder is appropriately categorised under HSN code 90189031 as a medical device with a GST rate of 12%.
Also, another issue raised was whether the product Bicarbonate bag is appropriately categorised under HSN code 28363000 at a GST rate 18%?
The AAR determined that the product ‘bicarbonate bag’ does not meet the criteria for classification as an instrument, appliance, or apparatus.
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Consequently, we will examine the relevant entry in the HSN. Chapter 28 of the Customs Tariff Act, 1975, pertains to inorganic chemicals, as well as organic or inorganic compounds of precious metals, radioactive elements, or isotopes. The HSN 28363000, particularly, deals with sodium bicarbonate.
| Name of Applicant | M/s. Soxa Formulations and Research Pvt. Ltd. |
| Advance Ruling No | GUJ/GAAR/R/2026/07 |
| GSTIN of the applicant | 24AAVCS8150M1ZL |
| Present for Applicant | Shri Brijesh Patel |
| Gujarat AAR | Read Order |
