GST Classification of Polished Limestone Slabs: AAR Ruling 02/2018
Polished limestone slabs are classified under HSN 6802, not Chapter 25, because polishing is considered advanced processing.
- Ruling
- TSAAR Order No. 2/2018, dated 25-03-2018
- Dated
- 25 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
- Maheshwari Stone Supplying Co. asked for the HSN classification of polished limestone.
- The company argued their product should remain under Chapter 25.
- The Authority ruled that polished stone falls under HSN 6802.
In short
The company asked the Telangana Authority for Advance Ruling (AAR) to confirm if their polished limestone slabs fall under Chapter 25 of the GST Tariff. They argued that their cutting and polishing process did not change the nature of the stone. The authority disagreed, stating that once stone is polished, it is no longer a crude mineral product.
What has changed
How it worked before
Many businesses assumed that all limestone products, regardless of processing, remained under the lower-taxed Chapter 25 categories.
What has changed
The authority decided that polished limestone must be classified under HSN 6802. In practice, this means businesses must check if their stone processing moves their product out of the crude mineral category and into the worked stone category, which may carry different tax implications.
Who this affects
Stone processors and suppliers who cut or polish limestone slabs.
An example
A stone supplier in another state processes rough limestone into polished tiles. They might assume they can use the HSN code for raw minerals. Based on this ruling, they should be aware that tax authorities may view their polished product as falling under HSN 6802 instead.
What you should do
If you process stone, review your HSN classification against this ruling. Remember that an advance ruling only binds the specific business that asked for it and their local tax office; it is not a universal law for all stone suppliers.
If you do nothing
If you classify your goods incorrectly, you risk paying the wrong amount of GST. A tax officer may issue a notice for the difference in tax, along with interest and penalties for underpayment. Do not assume this ruling protects you from scrutiny if your classification is challenged.
The terms explained
- HSN Code
- A system used to classify goods for tax purposes so that every product has a specific code.
- Chapter 25
- A section of the GST tariff that generally covers salt, sulfur, earths, stone, and plastering materials in their raw or crude state.
- Heading 6802
- A category in the GST tariff for worked monumental or building stone, including stone that has been polished or shaped.
The ruling in detail
Authority for Advance Ruling
M/s. Maheshwari Stone Supplying Co., Tandur
TSAAR Order No. 2/2018, dated 25-03-2018 · 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 it be classified as “Mineral substances not elsewhere specified or included” which is mentioned under HSN Code 2530?
- Can it be classified under any of the HSN Codes 2515/2516/2521?
- Can it be retained 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 engaged in the business of processing rough limestone slabs into polished slabs using a table polish machine and cutting them to size. They contended that their product should remain classified under Chapter 25, similar to how certain marble and granite products are treated, and argued that their process does not constitute manufacturing. They sought an advance ruling to confirm the classification of these polished limestone slabs under Chapter 25 of the GST Tariff.
Ruling
| Question | What the authority ruled |
|---|---|
| Classification of Polished/Processed limestone slabs | Heading 6802 The goods are worked beyond the stage of normal quarry products of Chapter 25 |
The Authority for Advance Ruling determined that the applicant's polished limestone slabs are not classifiable under Chapter 25. Instead, because the stones have been worked beyond the stage of normal quarry products, they are correctly classifiable under heading 6802. The ruling explicitly rejects the applicant's request to retain the goods under Chapter 25.
Reasoning
The Authority relied on the Explanatory notes to the Harmonized Commodity Description and Coding System, which state that Chapter 25 headings cover mineral products only in the crude state. It noted that stones which have undergone polishing are specifically excluded from headings 25.15 and 25.16. Conversely, heading 68.02 covers natural monumental or building stone that has been worked beyond the stage of normal quarry products, including those that have been polished. Therefore, the applicant's process of polishing and cutting brings the product under heading 6802.
Provisions relied on
- Section 97(1) of TGST Act, 2017
- Rule 103 of CGST/TGST Rules, 2017
- Heading 25.15 of GST Tariff
- Heading 25.16 of GST Tariff
- Heading 25.21 of GST Tariff
- Heading 68.02 of GST Tariff
For the practitioner
This ruling clarifies that **polished limestone slabs** are not considered crude mineral products and are therefore excluded from Chapter 25. Practitioners should note that any stone product subjected to **polishing or similar advanced processing** will likely be classified under heading 6802. This settles the classification for this specific process but does not address the taxability of raw, unpolished limestone.
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/tsaar_02-2018-telangana.pdf
Legibility of the scan, as read: high.
Prepared 16-10-2026.
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