GST Rate and HSN Classification for Railway Bellow Ducts
The Appellate Authority for Advance Ruling confirmed that custom-made railway bellows fall under HSN 8607, qualifying for a 12% GST rate.
- Ruling
- Appeal Order No. 15/AAAR/2021 dated 20.06.2021
- Authority
- Appellate Authority for Advance Ruling
This page was written by Patron Accounting’s AI from the official release and reviewed before publishing. It explains the document in plain language. It is not the document itself. Where this page and the original differ, the original governs.
The short version
- The company asked for the correct HSN code for railway bellows.
- The authority ruled these parts fall under HSN 8607.
- This classification attracts a 12% GST rate instead of 18%.
In short
The company asked whether their custom-made bellows for railway coaches should be taxed at 12% as railway parts or 18% as general mechanical appliances.
What has changed
How it worked before
Businesses were often unsure if custom-made parts for railways should be classified under specific railway headings or general industrial categories.
What has changed
The authority decided that because these bellows are designed exclusively for Indian Railways, they must be classified as railway rolling stock parts under HSN 8607. This confirms that specialized parts for railways benefit from the lower 12% tax rate.
Who this affects
Manufacturers of custom-built components specifically designed for Indian Railways coaches.
An example
Imagine a company that manufactures specialized rubber seals designed only for Indian Railway train doors. They might wonder if these are general rubber parts or railway parts. Based on this ruling, if the seals are made to specific railway designs and cannot be used elsewhere, they should likely be classified as railway parts under HSN 8607.
What you should do
If you manufacture similar custom parts, review your design specifications against this ruling. Remember that an advance ruling only binds the company that asked and its specific tax office; it is not a universal law for all businesses.
If you do nothing
If you classify your goods under the wrong HSN code, you risk paying the incorrect amount of tax. If a tax officer disagrees with your classification during an audit, you may be required to pay the difference in tax plus interest and potential penalties.
The terms explained
- HSN Code
- A standardized system of numbers used to classify goods for taxation purposes.
- Rolling Stock
- Any vehicle that moves on a railway, such as train coaches or locomotives.
- Advance Ruling
- A formal decision from tax authorities on how GST applies to a specific business transaction.
The ruling in detail
Appellate Authority for Advance Ruling
M/s CONCORD CONTROL SYSTEMS PRIVATE LIMITED
Appeal Order No. 15/AAAR/2021 dated 20.06.2021 · Uttar Pradesh
Questions before the authority
- What will be the HSN Code and GST Rate on supply of Bellow Duct to RDSO, Ministry of Railways for use in Indian Railways Coaches?
- Whether the supply of Bellow Duct to RDSO, Ministry of Railways for use in Indian Railway Coaches will fall under the HSN Code 8607 having GST rate of 12% or will it fall under HSN 8424 having GST rate of 18%?
Facts
The appellant is a limited company engaged in the supply of Bellow Ducts made of Meta Armid/Para Armid Fabric with Silicon Rubber Coating. These goods are manufactured according to specific designs and specifications issued by the RDSO, Ministry of Railways, and are used exclusively in the AC coaches of Indian Railways.
Ruling
| Question | What the authority ruled |
|---|---|
| Classification and GST rate of Bellow Duct | Classifiable under Chapter Heading 8607 The ruling specifically identifies the product as parts of railway rolling stock |
The Appellate Authority for Advance Ruling set aside the original order and ruled that the Bellow Ducts are correctly classifiable under Chapter Heading 8607. The authority concluded that because the products are specifically designed for and used solely by the Indian Railways, they qualify as parts of railway rolling stock.
Reasoning
The authority relied on the principle of the **suitability for use test** as affirmed by the Supreme Court in Westinghouse Saxby Farmer Ltd. It observed that since the Bellow Ducts are manufactured to specific designs for the Indian Railways and cannot be used in any other industry, they are not general-purpose mechanical appliances under Chapter 8424. The authority applied Chapter Note 3 of Chapter 86, which dictates that parts suitable for use solely or principally with railway articles must be classified under Chapter 86.
Provisions relied on
- Section 100 of the Central Goods and Service Tax Act, 2017
- Chapter Heading 8607 of the Customs Tariff Act, 1975
- Chapter Note 3 of Chapter 86
For the practitioner
This ruling is highly beneficial for manufacturers of **custom-built railway components** who face classification disputes between general industrial headings and specific railway headings. It reinforces the **sole or principal use test** for classifying parts under Chapter 86, even if the product might technically fit a description in another chapter. Practitioners should note that this decision emphasizes the importance of design specifications and exclusive supply arrangements in determining HSN classification.
Source
This is a summary prepared from the published order, which is a scanned document. It is a reading aid and not the authority: where the two differ, the order governs. Verify every provision against the original before relying on it.
Original order: https://www.gstcouncil.gov.in/sites/default/files/2024-02/up_aaar_15_2021-22_20.06.2021_ccspl.pdf
Legibility of the scan, as read: high.
Prepared 13-10-2026.
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