GST Classification and 5% Rate for Black Mineral Water
The Gujarat Authority for Advance Ruling confirmed that black mineral water without additives is classified under HSN 22011010 at a 5% GST rate.
- Ruling
- ADVANCE RULING NO. GUJ/GAAR/R/2026/16, dated 08/05/2026
- Dated
- 08 May 2026
- 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
- Oxyhydra Beverages asked for the correct HSN code for black mineral water.
- The product contains no added sugar, sweeteners, or flavorings.
- The authority classified the water under HSN 22011010.
- The applicable GST rate for this product is 5%.
In short
The company asked the Gujarat Authority for Advance Ruling (AAR) to clarify the Goods and Services Tax (GST) classification for its black mineral water brand, ALVA. Because the water is purified and infused with minerals but lacks sugar or flavorings, the company was unsure if it qualified as standard mineral water.
What has changed
How it worked before
Businesses were uncertain whether the unique composition of black mineral water required a different classification than standard bottled water.
What has changed
The authority ruled that adding minerals to purified water does not change its classification from mineral water. This confirms that such products fall under HSN 22011010 and are subject to a 5% GST rate.
Who this affects
Manufacturers and suppliers of mineral-infused water products without added sweeteners or flavorings.
An example
Imagine a company called PureFlow that makes alkaline mineral water without any flavorings. They are unsure if they should charge 5% or 18% GST. Based on this ruling, they can reasonably argue that their product also falls under HSN 22011010 at 5% GST, provided their manufacturing process is identical.
What you should do
If you produce similar water, you may use this ruling as a guide for your tax classification. However, an advance ruling only binds the company that requested it and their specific tax office; it is not a law that automatically applies to your business.
If you do nothing
If you apply this classification to your own products without confirming with your local tax officer, you risk being penalized for underpaying GST. A tax officer may disagree with your interpretation and demand the difference plus interest and penalties. Always consult with a professional to ensure your specific product matches the ruling's criteria.
The terms explained
- HSN
- Harmonized System of Nomenclature is a standardized system 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.
- Mineral Water
- Water that has been treated or processed to contain specific mineral content without added flavorings or sweeteners.
The ruling in detail
Authority for Advance Ruling
M/s. Oxyhydra Beverages Pvt. Ltd.
ADVANCE RULING NO. GUJ/GAAR/R/2026/16, dated 08/05/2026 · Gujarat
Questions before the authority
- Whether the supply of our black mineral water with brand name ALVA manufactured and supplied by the applicant is classifiable under HSN 22011010 (i.e. mineral waters and aerated waters : mineral waters) or some other HSN heading for the purpose of GST?
- In the event HSN 22011010 is not held applicable, the applicant requests the AAR to kindly specify the correct HSN heading and the GST rate applicable to the said product.
Facts
The applicant is engaged in the manufacture and supply of bottled water under the brand name ALVA. The product is produced by adding minerals to purified water and does not contain any added flavoring, sugar, or sweeteners. The applicant sought a ruling on the correct HSN classification and applicable GST rate for this product.
Ruling
| Question | What the authority ruled |
|---|---|
| Classification of black mineral water | Classifiable under HSN 22011010 None |
| Applicable GST rate | 5% (2.5% CGST + 2.5% SGST) As per Entry No. 146 of Schedule I of Notification No. 09/2025-Central Tax (Rate) |
The authority ruled that the product is classifiable under HSN 22011010. It further determined that the product falls under Entry No. 146 of Schedule I of Notification No. 09/2025-Central Tax (Rate) and is liable to GST at the rate of 5%.
Reasoning
The authority examined the manufacturing process and laboratory reports, confirming the product contains no added sugar, sweeteners, or flavorings. It relied on the First Schedule to the Customs Tariff Act, 1975, which classifies mineral waters under heading 2201. The authority concluded that the addition of minerals does not preclude classification under 22011010. Consequently, it applied the rate specified in Notification No. 09/2025-Central Tax (Rate) for goods falling under this heading.
Provisions relied on
- Section 97(2)(a) of the CGST/GGST Act, 2017
- Chapter 22 of the First Schedule to the Customs Tariff Act, 1975
- Notification No. 09/2025-Central Tax (Rate) dated 17.09.2025
For the practitioner
This ruling confirms that **black mineral water** without added sugar or flavorings is classified under **HSN 22011010** and attracts a **5% GST rate**. It provides clarity for manufacturers of similar mineral-infused water products regarding their tax liability. It does not apply to products containing added sweeteners or flavorings, which would likely fall under different classifications.
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/2-oxyhydra_beverages_pvt_ltd_0001_compressed_1.pdf
Legibility of the scan, as read: high.
Prepared 11-10-2026.
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