GST Rate for E-Rickshaw Tyres: Maharashtra Advance Ruling
The Maharashtra Authority for Advance Ruling decided that e-rickshaw tyres are taxable at 28 percent GST.
- Ruling
- NO.GST-ARA-07/2017/B-10 Mumbai, dt. 09/03/18
- Dated
- 09 Mar 2018
- 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
- Ceat Limited asked if e-rickshaw tyres qualify for lower cycle rickshaw tax rates.
- The authority ruled e-rickshaws are motor vehicles, not human-powered cycle rickshaws.
- E-rickshaw tyres fall under Tariff Heading 4011 at a 28 percent GST rate.
In short
The company asked whether tyres for electric rickshaws should be taxed at the lower rate meant for cycle rickshaws or the higher rate for standard pneumatic tyres. The authority examined whether an e-rickshaw, which is a motorized vehicle, fits the definition of a traditional cycle rickshaw.
What has changed
How it worked before
Businesses were uncertain if the evolution of cycle rickshaws into electric versions allowed them to claim the lower tax benefits originally intended for human-powered transport.
What has changed
The authority confirmed that e-rickshaws are motor vehicles requiring registration and lack pedals, meaning they do not qualify for the concessional tax rate. In practice, manufacturers and sellers must apply the 28 percent GST rate to these tyres.
Who this affects
Manufacturers, distributors, and retailers of tyres specifically designed for electric three-wheeled vehicles.
An example
A local tyre manufacturer produces rubber tyres for electric three-wheelers and wants to apply the lower cycle rickshaw tax rate. Based on this ruling, they cannot claim that lower rate because their product is for a motorized vehicle. They must charge 28 percent GST to remain compliant with the current classification.
What you should do
If you sell e-rickshaw tyres, you should apply the 28 percent GST rate. 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 apply a lower tax rate based on an incorrect interpretation, you risk a tax demand notice for the unpaid difference. You may also be liable for interest and penalties if an audit reveals you underpaid your GST liability.
The terms explained
- Tariff Heading 4011
- A specific category in the GST tax schedule that covers new pneumatic tyres made of rubber.
- Advance Ruling
- A formal decision provided by tax authorities to a business regarding how tax laws apply to their specific products or services.
- Concessional rate
- A lower tax rate offered by the government to encourage specific industries or support essential goods.
The ruling in detail
Authority for Advance Ruling
M/s Ceat Ltd.
NO.GST-ARA-07/2017/B-10 Mumbai, dt. 09/03/18 · Maharashtra
Questions before the authority
- What is the classification and rate of Central Goods and Service Tax leviable on the product E-rickshaw tyres?
Facts
The applicant is engaged in the manufacture of rubber tyres, including those specifically designed for three-wheeled electric rickshaws. They sought an advance ruling to determine if these tyres fall under the lower tax bracket applicable to cycle rickshaws or the higher bracket for general pneumatic tyres. The applicant argued that e-rickshaws are an evolution of powered cycle rickshaws and should be treated similarly for tax purposes.
Ruling
| Question | What the authority ruled |
|---|---|
| E-rickshaw tyres | 14% CGST (28% total) Classified under Tariff Heading 4011 |
The Authority ruled that e-rickshaw tyres are not covered under the entry for cycle rickshaws. Consequently, the product is classified under Tariff Heading 4011 and is subject to a total GST rate of 28 percent, comprising 14 percent CGST and 14 percent MGST.
Reasoning
The Authority reasoned that e-rickshaws are distinct from cycle rickshaws as they are motor vehicles requiring registration and lack pedals. Applying the principle of **noscitur a sociis**, the Authority concluded that the term cycle rickshaw in the relevant notification refers only to human-powered vehicles. Therefore, the tyres do not qualify for the concessional 2.5 percent CGST rate intended for cycle rickshaws. The ruling relies on the interpretation of entries in Notification No. 1/2017-Central Tax (Rate) and the distinction between motor vehicles and non-motorized cycles.
Provisions relied on
- Section 95 of the CGST Act, 2017
- Section 96 of the Maharashtra Goods and Service Tax Act, 2017
- Notification No. 1/2017-Central Tax (Rate) dated 30.06.2017
- Tariff Heading 4011
For the practitioner
This ruling clarifies that e-rickshaw tyres are **taxable at the higher rate** of 28 percent rather than the concessional rate applicable to cycle rickshaws. It serves as a precedent for distinguishing between motorized e-rickshaws and traditional cycle rickshaws in tax classification. Practitioners should note that this decision strictly separates modern electric vehicles from legacy definitions of cycle-based transport.
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/maharashtra_gst-ara-07_2017_dt_9.3.18_ceat_l.pdf
Legibility of the scan, as read: high.
Prepared 12-10-2026.
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.