HSN Classification of Polypropylene Packing Boxes: West Bengal AAR Ruling in the Case of Jai Hind Plastic
Background and Nature of the Application
The Authority for Advance Ruling (AAR), West Bengal, was approached by Jai Hind Plastic, a manufacturer registered under GST in West Bengal, seeking a formal determination of the correct HSN classification for its product — PP (Polypropylene) Packing Boxes.
The applicant had been engaged in the manufacture and commercial supply of these plastic packing boxes and had, at the time of filing the application, been classifying them under HSN Code 392390, falling within Chapter 3923 of the Customs Tariff. This chapter broadly covers "articles for the conveyance or packing of goods of plastics; stoppers, lids, caps and other closures of plastics."
The tax being levied on these products was 18% GST, split as 9% CGST and 9% SGST, in accordance with the applicable rate notification. There was no contention raised by the applicant with respect to the rate of tax — the sole objective of approaching the AAR was to confirm the precise HSN Code applicable to PP Packing Boxes, so as to ensure complete and accurate compliance under GST law.
The application was filed under Section 97(1) of the GST Act, and the question raised was held to be admissible under Section 97(2)(a), which covers disputes or clarifications relating to the classification of goods. The Revenue raised no objection to the admission of the application, and accordingly it was admitted for consideration.
Manufacturing Process and Product Description
As submitted before the AAR, the applicant manufacturers PP Packing Boxes at its factory located at 284, Maharaja Nanda Kumar Road, Alambazar, Kolkata – 700035. The principal raw material used in the manufacturing process is plastic granules, which are processed through semi-automatic machines installed at the factory premises to produce the finished product.
The applicant clarified that the PP Packing Boxes are sometimes supplied along with stoppers, lids, caps, and closures, and on other occasions, they are supplied without such accessories. To assist the Authority, the applicant placed on record specimen invoices reflecting the product descriptions as well as photographs of the goods.
From a review of the invoices, it was noted that the applicant had been using HSN Code 39239090 while charging GST at 9% CGST + 9% SGST for intra-state supplies, and 18% IGST for inter-state supplies.
The applicant's position was that these products fall under Serial No. 124 of Schedule II of Notification No. 01/2017 – Central Tax (Rate) dated 28.06.2017, as amended by Notification No. 09/2025 – Central Tax (Rate) dated 19.09.2025, which describes goods as:
"Articles for the conveyance or packing of goods, of plastics; stoppers, lids, caps and other closures, of plastics."