GST Classification of Polished Limestone Slabs: AAAR/01/2018
The Appellate Authority for Advance Ruling ruled that polished limestone slabs fall under Chapter 68, not Chapter 25, for GST purposes.
- Ruling
- A.R.Appeal-No. AAAR/01/2018 dated 07 August, 2018
- 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
- Polished limestone slabs are classified under HSN heading 6802.
- Processes like polishing and calibration move stone out of Chapter 25.
- The ruling confirms processed stone is not a raw mineral product.
In short
Maheshwari Stone Supplying Co. asked if their polished limestone slabs should be taxed as raw minerals under Chapter 25 or as worked stone under Chapter 68. The authority decided that because the stone underwent polishing, cutting, and calibration, it is no longer a crude mineral product.
What has changed
How it worked before
Many small-scale stone processors assumed that because the fundamental substance of the stone remained limestone, it should stay classified under the mineral category of Chapter 25.
What has changed
The authority ruled that once stone is polished or calibrated, it becomes 'worked monumental or building stone' under heading 6802. This means businesses must classify these goods under Chapter 68, which typically carries a different tax treatment than raw minerals.
Who this affects
Stone processors, quarry owners, and businesses involved in cutting, polishing, or calibrating limestone or similar natural stones.
An example
A marble processor in Telangana performs similar polishing and calibration on their slabs. They might wonder if they can still use the HSN code for raw minerals. Based on this ruling, the tax department would likely argue that their processed marble also falls under heading 6802, potentially leading to a tax dispute if they continue to use the lower-tax mineral classification.
What you should do
If you process stone, review your HSN classification against this ruling. Remember that an Advance Ruling only binds the business that requested it and their specific tax office; it is not a universal law for all stone processors.
If you do nothing
If you classify your goods incorrectly, a tax officer may issue a notice for tax evasion or misclassification. You could be liable for the difference in tax, interest, and penalties. Relying on a ruling that does not apply to you provides no legal protection during an audit.
The terms explained
- HSN Code
- A standardized system of names and numbers used to classify traded products for tax purposes.
- Chapter 25
- A section of the tax tariff covering salt, sulfur, earths, stone, and raw mineral products.
- Chapter 68
- A section of the tax tariff covering articles of stone, plaster, cement, asbestos, or similar materials.
The ruling in detail
Appellate Authority for Advance Ruling
M/s. Maheshwari Stone Supplying Company, Tandoor, Vikarabad District
A.R.Appeal-No. AAAR/01/2018 dated 07 August, 2018 · Telangana
Questions before the authority
- In which Chapter the commodity called "Polished / Processed limestone slabs" falls ?
- Under which HSN Code the above commodity comes ?
- Can we put them under "Mineral substances not elsewhere specified or included" which is mentioned under HSN Code 2530 ?
- Can we retain them under any of the HSN Codes 2515/2516 ?
- Can we retain them under HSN Code 25 with inaugural phrase of "Goods not mentioned elsewhere" as mentioned at the start of column of 5% ?
Facts
The applicant is a small-scale unit that processes rough limestone slabs by polishing, cutting, tumbling, and calibration. They argued that their processed limestone slabs should remain classified under Chapter 25 as mineral products, as the processing does not change the fundamental nature or character of the stone. The lower authority had previously ruled that the goods were classifiable under heading 6802.
Ruling
| Question | What the authority ruled |
|---|---|
| Chapter classification | Chapter 68 The commodity falls under Chapter 68 of the First Schedule to the Customs Tariff Act, 1975. |
| HSN Code | 6802 92 00 Classified as Other calcareous stone under heading 6802. |
| Classification under 2530 | No The goods do not fall under HSN Code 2530. |
| Classification under 2515/2516 | No The goods do not fall under HSN Codes 2515 or 2516. |
| Classification under Chapter 25 | No The goods would not fall under Chapter 25. |
The Appellate Authority upheld the classification of the processed limestone slabs under Chapter 68, specifically heading 6802. It concluded that the processes undertaken by the applicant go beyond those permitted for classification under Chapter 25, thereby moving the goods into the category of worked monumental or building stone.
Reasoning
The authority reasoned that the processes of polishing, tumbling, and calibration are **beyond the scope of processes permitted** under Chapter 25 for mineral products. It relied on Note 1 to Chapter 25, which restricts the chapter to products in a crude state or subjected to specific, limited processes. Consequently, the goods are classified as **worked monumental or building stone** under heading 6802, as they have been worked beyond the stage of normal quarry products. The authority also noted that the classification is governed by the Customs Tariff Act, 1975, and relevant HSN Explanatory Notes.
Provisions relied on
- Section 101(1) of the Telangana Goods and Services Tax Act, 2017
- Chapter 25 of the Customs Tariff Act, 1975
- Chapter 68 of the Customs Tariff Act, 1975
- Heading 6802 of the Customs Tariff Act, 1975
- Note 1 to Chapter 25 of the Customs Tariff Act, 1975
For the practitioner
This ruling clarifies that processed limestone slabs subjected to polishing and other mechanical processes are **not classifiable under Chapter 25** as raw minerals. Practitioners should note that the authority prioritizes the **nature of processing** over the applicant's argument regarding the small-scale nature of the business or the lack of change in the stone's fundamental substance. It confirms that such processed stone falls under the higher tax bracket associated with heading 6802.
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/aaar-01-2018-maheshwari_stone.pdf
Legibility of the scan, as read: high.
Prepared 13-10-2026.
About Patron Accounting LLP
Patron Accounting LLP is a CA and CS-led accounting and compliance firm that has been working with businesses across India since 2019. We handle the work that keeps a company correct with every department it answers to: day-to-day bookkeeping and accounting, GST registration and returns, income tax filing and assessments, TDS, payroll and PF/ESI, company and LLP incorporation, ROC and MCA compliance, statutory and internal audit, physical stock and inventory audits, trademark and other registrations, and the certificates and reports that banks, buyers and regulators ask for.
Our clients range from a first proprietorship registering for GST to established companies running operations across several states. Much of our work is exactly this: reading what a department has published and telling a business, in plain terms, whether it changes anything for them.
We operate from five offices and serve clients across the rest of India remotely:
- Pune (HQ): RTC Silver, B4-708, Sai Satyam Park, Wagholi, Pune, Maharashtra 412207
- Mumbai: 104, Rajshila Building, 597 J.S.S. Road, Marine Lines, Mumbai 400002
- Delhi: 3rd Floor, B-6/154-155, Sector 5, Rohini, Delhi 110085
- Gurugram: Pioneer Urban Square, B109, Golf Course Ext Road, Sector 62, Gurugram 122098
- Ahmedabad: Phoenix Tower, 1107, near Commerce Six Road, Drive In Road, Navrangpura, Ahmedabad, Gujarat 380009
If anything on this page affects you and you would like somebody to look at your own position, we are glad to help. Call +91 94594 56700, write to sales@patronaccounting.com, or visit patronaccounting.com. The first conversation costs nothing.