The West Bengal Authority for Advance Ruling (AAR), in a ruling, has stated that electric three-wheeler vehicles (e-rickshaws) supplied in Completely Knocked Down (CKD) form shall be treated as finished vehicles and be eligible for the concessional 5% Goods and Services Tax (GST) rate only when the kit comprises the motor along with at least three other critical components namely, the transmission, axles, chassis, and controller.
The appeal has arrived from the applicant, Navya Electric Vehicle Pvt. Ltd., which asked for clarity on whether supplying e‑rickshaw kits in CKD condition must be taxed as a complete vehicle or as individual parts.
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The petitioner mentioned that his plan to supply vehicles in a Completely Knocked Down (CKD) condition must be considered as the supply of a finished vehicle instead of mere parts.
It mentioned that the CKD kit consists of all important parts like chassis, motor, battery, controller, body panels, and differential delivered together in a single consignment to authorised dealers or assemblers, who then assemble and sell the road‑worthy e‑rickshaw.
It mentioned that a clarification is needed for the classification of the same CKD kit and the related Goods and Services Tax rate (GST), as the tax rate for the finished electric vehicle (typically 5%) varies from the tax rates applicable to various individual parts (which may be 18% or 28%)
The revenue does not specify any opinion on the merit of the problem raised by the applicant.
AAR post analysing the case noted and referred to Rule 2(a) of the General Rules for Interpretation of the Customs Tariff Act, 1975, and earlier judicial precedents, the authority outlined that crucial character test. The same test requires that even unassembled kits could be considered as finished goods if they carry the crucial elements that describe the product.
The bench, Shafeeq S and Jayadip Kumar Chakrabarti ( Member of West Bengal Authority for Advance Ruling) stated that CKD kits, along with the motor plus at least three of the other four components, are to be considered as finished vehicles and are taxed at 5% GST. Kits missing the motor or two of those parts are considered parts, taxed at 18% GST.
| Name of the Applicant | Navya Electric Vehicle Private Limited |
| GSTIN | 19AAICN1800C1ZW |
| Case Number | WBAAR 24 of 2025-26 |
| Applicant’s representative heard | Mr Priya Ranjan Shukla |
| WB GST AAR | Read Order |
