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Advance rulings (AAR) Tamil Nadu

GST Rate for Two-Wheeler Seat Covers: Tamil Nadu Advance Ruling

The Tamil Nadu Authority for Advance Ruling confirmed that bike and scooter seat covers are taxable at a 28% GST rate.

Ruling
Advance Ruling No. 105/AAR/2023 Dated: 05.09.2023
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

  1. Lion Seat Cushion Pvt Ltd asked for the correct GST rate on seat covers.
  2. The authority classified seat covers under HSN code 87149990.
  3. Seat covers for two-wheelers are subject to a 28% GST rate.
  4. This rate includes 14% CGST and 14% SGST.

In short

The company asked the Tamil Nadu Authority for Advance Ruling (AAR) to confirm the GST rate for bike and scooter seat covers. Because manufacturers were using different tax codes, there was confusion about whether these items should be taxed at a lower rate or the higher 28% rate. The authority clarified that these products are accessories for two-wheelers and must be taxed at 28%.

What has changed

How it worked before

Businesses were uncertain about the correct HSN code for seat covers, with some applying lower tax rates based on different interpretations of vehicle parts and seat classifications.

What has changed

The authority confirmed that seat covers fall under HSN 87149990, which carries a 28% GST rate. This means manufacturers must ensure they are collecting and paying the full 28% tax to remain compliant with GST regulations.

Who this affects

Manufacturers and traders of bike and scooter seat covers across India.

An example

Imagine a business called 'Speedy Seats' that manufactures scooter seat covers. They were previously charging 18% GST, believing their product was a general seat accessory. After reading this ruling, they realize the tax department classifies their product under HSN 87149990. Speedy Seats should now update their billing to 28% GST to avoid potential tax demands or penalties during an audit.

What you should do

If you sell two-wheeler seat covers, you should review your current tax classification to ensure it matches this ruling. Please note that an advance ruling is only legally binding for the company that requested it and its specific tax officer. It serves as a guide for how the department views this product, but it does not automatically change the law for your business.

If you do nothing

If you continue to use a lower tax rate based on a different interpretation, your local tax officer may disagree with your classification. This can lead to a tax demand for the unpaid difference, along with interest and potential penalties. Relying on a ruling that does not apply to you does not protect you from these consequences.

The terms explained

HSN code
A standardized system of numbers used to classify goods for taxation purposes.
Advance Ruling
A formal decision provided by tax authorities to a business regarding the tax treatment of a specific transaction.
CGST and SGST
The two components of GST; CGST is collected by the central government, and SGST is collected by the state government.

The ruling in detail

Authority for Advance Ruling

M/s. Lion Seat Cushions Private Limited

Advance Ruling No. 105/AAR/2023 Dated: 05.09.2023 · Tamil Nadu

Questions before the authority

  • Whether the GST rate of 28% collected and paid by the Applicant for Bike and Scooter seat cover is correct.

Facts

The applicant manufactures seat covers for two-wheelers by cutting foam and stitching rexine sheets. They sought an advance ruling to determine the correct HSN classification and tax rate for these products, noting that competitors were using different HSN codes and lower tax rates. The applicant previously paid 28% GST but requested clarification to remain competitive in the market.

Ruling

QuestionWhat the authority ruled
Classification and tax rate for two-wheeler seat coversClassified under CTH 87149990, taxable at 14% CGST + 14% SGST
As per entry no. 174 of Schedule IV of Notification No. 1/2017- CT(Rate), dated 28.06.2017, as amended

The Authority ruled that the seat covers are classified under CTH 87149990. Consequently, they are subject to a total GST rate of 28%, consisting of 14% CGST and 14% SGST.

Reasoning

The Authority determined that the seat covers are accessories to two-wheelers and do not fall under CTH 8708 (parts of motor vehicles 8701-8705) or CTH 9401 (seats). Instead, they fall under CTH 8714, which covers parts and accessories of vehicles of headings 8711 to 8713. Specifically, they are classified under CTH 87149990. The ruling relies on **Notification No. 1/2017- CT(Rate)**, which mandates a 28% tax rate for items under heading 8714.

Provisions relied on

  • Section 98(4) of the CGST Act, 2017
  • Section 98(4) of the TNGST Act, 2017
  • Section 103(1) of the Act
  • Section 103(2) of the Act
  • Section 104 of the Act
  • Notification No. 1/2017- CT(Rate) dated 28.06.2017
  • Notification No. 24/2018- CT(Rate) dated 31.12.2018

For the practitioner

This ruling clarifies that two-wheeler seat covers are **taxable at 28%** under HSN 87149990. It settles the classification dispute for manufacturers who were previously uncertain between HSN 8708, 9401, and 8714. Practitioners should note that this confirms the higher tax bracket for such accessories, rejecting the lower rates adopted by some competitors.

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/105_lion_seat_cusion.pdf

Legibility of the scan, as read: high.

Prepared 13-10-2026.

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Is this 28% rate binding on my business in a different state?

No. An advance ruling is only binding on the business that requested it and the tax authorities in that specific jurisdiction. However, it provides a clear indication of how the tax department interprets the law for this product.

What if my local tax officer disagrees with this ruling?

Since this ruling is not a law that applies to everyone, your local tax officer is not strictly bound by it. They may still conduct their own assessment of your product classification.

Can I use this ruling to justify a lower tax rate?

No, this ruling specifically confirms that the higher 28% rate is the correct one for two-wheeler seat covers. It does not support the use of lower tax rates.

Does this ruling apply to car seat covers as well?

The ruling specifically addresses seat covers for two-wheelers (bikes and scooters). It does not provide a classification for car seat covers.