GST Classification of Car Seat Covers: AAR No. 13/AP/GST/2023
The Andhra Pradesh Authority for Advance Ruling confirmed that car seat covers are classified as motor vehicle accessories taxable at 28% GST.
- Ruling
- AAR No.13/AP/GST/2023 dated 15.12.2023
- 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
- The company asked if car seat covers fall under HSN 9401 at 18% GST.
- The Authority ruled these are parts and accessories under HSN 8708.
- The applicable GST rate for these items is 28%.
- Previous rulings on the same product remain binding for the applicant.
In short
The company asked the Andhra Pradesh Authority for Advance Ruling (AAR) to classify car seat covers as 'seats' under HSN 9401 to benefit from an 18% GST rate. The authority examined whether these covers, which are permanently fitted to vehicle seats, should be treated as part of the seat itself or as a separate vehicle accessory.
What has changed
How it worked before
Businesses often debated whether seat covers integrated into the manufacturing process could be classified as part of the seat assembly rather than as a separate vehicle accessory.
What has changed
The authority decided that these seat covers are classified under HSN 8708 as motor vehicle parts and accessories. This means they are subject to the higher 28% GST rate, rejecting the attempt to classify them under the 18% category.
Who this affects
Manufacturers and suppliers of automotive seat covers or interior components for original equipment manufacturers (OEMs).
An example
Imagine a company that manufactures custom-fitted leather seat covers for car manufacturers. They might hope to classify these as 'seats' to pay 18% GST. Based on this ruling, the tax department would likely classify their product as a vehicle accessory under HSN 8708, requiring them to pay 28% GST instead.
What you should do
If you manufacture similar products, you should review your current GST classification. Note that an advance ruling only binds the specific company that asked for it and their local tax office; it is not a general law for all businesses. You should consult with your tax advisor to determine if your specific product design warrants a different classification.
If you do nothing
If you assume this ruling allows you to pay a lower rate, you risk a tax demand notice for the difference in GST. Tax officers may impose penalties and interest for underpayment if they disagree with your classification. Relying on a ruling that does not apply to your specific business can lead to costly legal disputes.
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.
- OEM
- Original Equipment Manufacturer refers to the company that produces the parts or equipment used in the final vehicle assembly.
The ruling in detail
Authority for Advance Ruling
M/s.Saddles International Automotive & Aviation Interiors Private Limited
AAR No.13/AP/GST/2023 dated 15.12.2023 · Andhra Pradesh
Questions before the authority
- Whether original car seat covers which are manufactured and designed to permanently fit over the raw foam seat of the vehicles by the OEMs as well as the seat manufacturers who further sell to OEMs and are sold with the vehicle as an essential and integral part of seat is classifiable under HSN 9401 as Seats (other than those of heading 9402) whether or not convertible into beds, and parts thereof (other than seats of a kind used for aircraft) and is liable to GST @ 18% vide Sl. No. 435A under Schedule III of Notification No. 1/2017 Central tax (rate) dt. 28.06.2017 as amended by Notification no. 41/2017 Central Tax (rate) dt. 14.11.2017.
Facts
The applicant manufactures original car seat covers designed to be permanently affixed over raw foam seats by OEMs. These covers are considered an integral part of the seat assembly, without which the vehicle is incomplete and cannot be sold. The applicant sought a ruling on the classification of these specific seat covers.
Ruling
| Question | What the authority ruled |
|---|---|
| Classification and GST rate for original car seat covers | Classifiable under HSN 8708, liable to GST @ 28% (14% CGST + 14% SGST) The ruling rejects the applicant's contention for HSN 9401 and 18% GST |
The Authority ruled that the seat covers are not classifiable under HSN 9401. Instead, they are classified under HSN 8708 as parts and accessories of motor vehicles. Consequently, they are liable to GST at the rate of 28% (14% CGST + 14% SGST).
Reasoning
The Authority observed that the issue was previously covered by an earlier ruling for the same applicant, which held that such seat covers fall under HSN 8708. It noted that the applicant's attempt to distinguish the current case as involving a 'seat shell' did not change the fundamental nature of the product as an accessory. The Authority relied on Section 103(2) of the CGST Act, stating that the previous ruling remains binding unless there is a substantial change in facts. It concluded that the goods are parts and accessories of motor vehicles under HSN 8708.
Provisions relied on
- Section 97(2) of CGST/APGST Act, 2017
- Section 98 of CGST/APGST Act, 2017
- Section 103(2) of CGST Act
- Notification No. 1/2017-Central Tax (Rate)
For the practitioner
This ruling serves as a **negative precedent** for manufacturers seeking to classify permanent car seat covers under HSN 9401 to avail a lower 18% GST rate. It reinforces the **binding nature of previous advance rulings** on the same applicant regarding the same product. Practitioners should note that the Authority maintains the classification of these items under HSN 8708, attracting the higher 28% GST rate.
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/13_saddles_international_automotive_aviation_interiors_pvt_ltd.pdf
Legibility of the scan, as read: high.
Prepared 13-10-2026.
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