The Rajasthan Authority for Advance Ruling (AAR) has stated that paper bags are correctly classified under Heading 4819 and fall under Entry 185 of Schedule I of Notification No. 09/2025–Central Tax (Rate), attracting GST at the rate of 18%.
The bench of Utkarsha and Dr Akhedan Charan has mentioned that, as the paper bags are neither a corrugated carton (4819 10) nor a non-corrugated carton (4819 20), the product falls under the residual category of Heading 4819. Thus Entry 185 applies, drawing GST at 18% (9% CGST + 9% SGST).
The petitioner, M/s SGS Packaging Private Limited, is in the manufacture and supply of paper bags used for packaging.
The petitioner has sought the advance ruling concerning the applicability of the GST rate for paper bags manufactured and supplied by them, and whether the same would fall under the 5% or 18% rate slab in terms of Notification No. 09/2025-Central Tax (Rate) dated 17.09.2025, which substitutes the earlier Notification No. 01/2017-Central Tax (Rate) dated 28.06.2017.
The Supreme Court in the case of Safari Retreats Pvt. Ltd. v. Chief Commissioner of CGST, stated that the expression “plant or machinery” used in the statute should be interpreted in its natural disjunctive sense, signifying that the two expressions function independently and cannot be blended or replaced.
The Court compared the same with the phrase “plant and machinery,” which carries a conjunctive meaning and requires both elements to be read together. Applying the same interpretative logic to Entry 319, the phrase “Paper Sacks/Bags and bio-degradable bags” should be understood conjunctively, so that the expressions appearing on either side of “and” are read in continuity.
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As per the applicant, the entry comprises biodegradable paper bags, and the conjunction implies a combined reading instead of separate product categories.
AAR has analysed Entry 322 of Schedule I, which grants 5% rate only to “Cartons, boxes and cases” of corrugated or non-corrugated paper or paperboard. As the applicant manufactures “bags” and not cartons or cases, this entry is not applicable, as the petitioner said that they are engaged in making paper bags.
| Case Title | M/s SGS Packaging Private Limited |
| GSTIN of the Applicant | 08ABPCS8202B1ZD |
| Date of Ruling | 17.12.2025 |
| Present for the Applicant | Mr Ranjan Mehta and Veena Babani (C.A.) |
| Rajasthan GST AAR | Read Order |
