GST Rate for Fuel Injection Pump Parts: TN/117/AAR/2023 Explained
The Tamil Nadu Authority for Advance Ruling confirmed that specific fuel injection pump parts are taxable at 18% GST.
- Ruling
- Advance Ruling No.117/AAR/2023 Dated: 22.11.2023
- Authority
- 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
- Delphi TVS Technologies asked for the correct GST classification of pump parts.
- The Authority ruled these parts fall under HSN 84139190.
- These parts are taxable at 18% under the residual entry of Schedule III.
In short
The company asked whether specific parts for fuel injection pumps should be taxed at the higher rate applied to the pumps themselves or at a lower residual rate. The Authority for Advance Ruling (AAR) examined the Customs Tariff Act and determined that because these are parts and not the pumps themselves, they qualify for a lower tax bracket.
What has changed
How it worked before
Businesses often assumed that parts of fuel injection pumps should be taxed at the same 28% rate as the pumps themselves.
What has changed
The ruling clarifies that these parts fall under the residual entry at 18% GST. This means manufacturers and suppliers of these specific components may be overpaying tax if they are currently charging 28%.
Who this affects
Manufacturers and suppliers of automotive fuel injection pump components.
An example
Imagine a small auto-parts manufacturer in Tamil Nadu producing similar pump components. They have been charging 28% GST based on the assumption that parts follow the pump's tax rate. After reading this ruling, they should consult a tax professional to see if their specific parts qualify for the 18% rate, but they cannot simply change their tax filing based on this document alone.
What you should do
Review your current HSN classification and tax rates for pump parts. Note that an Advance Ruling is only binding on the company that requested it and their specific tax officer; it is not a universal law for all businesses.
If you do nothing
If you unilaterally change your tax rate based on this ruling, your local tax officer may disagree with your classification. This could lead to notices for short-payment of tax, interest charges, and potential penalties for incorrect filing.
The terms explained
- HSN
- Harmonized System of Nomenclature is a standardized system used to classify goods for taxation purposes.
- Residual entry
- A catch-all category in tax law for items that do not fit into more specific, named categories.
- Advance Ruling
- A formal decision provided by tax authorities to a business regarding the tax treatment of a specific transaction.
The ruling in detail
Authority for Advance Ruling
M/S DELPHI TVS TECHNOLOGIES LIMITED
Advance Ruling No.117/AAR/2023 Dated: 22.11.2023 · Tamil Nadu
Questions before the authority
- Whether the following parts of fuel injection pumps manufactured/procured indigenously/imported and supplied by the Applicant are classifiable under HSN 84139110/ 84139190 and taxable under Sl. No. 453 (goods which are not specified in Schedule I, II, IV, and VI) of Schedule III of Notification No. 01/2017-Integrated Tax (Rate) dated 28.06.2017? a. Assy Head & Rotor b. X Roller & Shoe Kit c. Kit Excess Piston d. Hyd head Assy for Tata Ace
- Whether the following parts of fuel injection pumps manufactured/procured indigenously/imported and supplied by the Applicant are classifiable under HSN 84139130/ 84139190 and taxable under Sl. No. 453 (goods which are not specified in Schedule I, II, IV, and VI) of Schedule III of Notification No. 01/2017-Integrated Tax (Rate) dated 28.06.2017? a. TP Blade/ Spring Kit (Set of 4 Nos) b. TP Liner
Facts
The applicant is engaged in the manufacture and supply of fuel injection pumps and their parts for automobiles. They sought an advance ruling on the correct HSN classification and applicable GST rate for various specific parts of these fuel injection pumps. The applicant previously classified these parts under HSN 84139190 and discharged GST at 28%.
Ruling
| Question | What the authority ruled |
|---|---|
| Classification and rate for Assy Head & Rotor, X Roller & Shoe Kit, Kit Excess Piston, and Hyd head Assy for Tata Ace | Classifiable under CTH 84139190 and taxable under Sl. No. 453 of Schedule III of Notification No. 01/2017-Integrated Tax (Rate) at 18% IGST. None |
| Classification and rate for TP Blade/ Spring Kit (Set of 4 Nos) and TP Liner | Classifiable under CTH 84139190 and taxable under Sl. No. 453 of Schedule III of Notification No. 01/2017-Integrated Tax (Rate) at 18% IGST. None |
The Authority ruled that the specified parts of fuel injection pumps are classifiable under HSN 84139190. It further held that these goods are taxable at 18% IGST under Sl. No. 453 of Schedule III of Notification No. 01/2017-Integrated Tax (Rate).
Reasoning
The Authority determined that the parts of fuel injection pumps do not fall under the specific entry for fuel injection pumps (Sl. No. 117 of Schedule IV) which covers only the pumps themselves and not their parts. Consequently, the parts fall under the **residual entry** at Sl. No. 453 of Schedule III of the IGST Notification. The classification under CTH 84139190 was confirmed as the appropriate heading for 'parts of pumps - others'. The ruling relies on the interpretation of the Customs Tariff Act and the specific scope of the IGST rate notifications.
Provisions relied on
- Section 97(2) of the CGST/TNGST Act
- Notification No. 01/2017-Integrated Tax (Rate) dated 28.06.2017
- First Schedule to the Customs Tariff Act, 1975
For the practitioner
This ruling clarifies that parts of fuel injection pumps are not subject to the 28% rate applicable to the pumps themselves, but rather the **18% residual rate** under Sl. No. 453 of Schedule III. It provides a clear precedent for manufacturers of automotive components to re-evaluate their tax liability if they have been discharging tax at the higher rate. It does not decide on the classification of parts that might fall under more specific headings if they were not 'parts of pumps - others'.
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/AAR/117_delphi_tvs.pdf
Legibility of the scan, as read: high.
Prepared 13-10-2026.
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