GST Rates for Carved Stone and Building Materials: RAJ/AAR/2026-27/02
The Rajasthan Authority for Advance Ruling clarified that structural stone products remain taxed as building materials regardless of their ornamental carvings.
- Ruling
- RAJ/AAR/2026-27/02, dated 11.06.2026
- Dated
- 11 Jun 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
- Structural stone items like pillars and wall claddings are not artware.
- Ornamental carving does not change the primary tax rate for building materials.
- Only standalone decorative items qualify for the concessional 5% GST rate.
- The ruling uses the essential character test to determine tax classification.
In short
The company asked if their carved stone products, such as pillars and wall claddings, could be taxed at a lower 5% GST rate meant for art. The authority decided that because these items serve a structural or architectural purpose, they must be taxed at the standard rate for building materials, not the lower rate for decorative art.
What has changed
How it worked before
Many businesses assumed that adding artistic carvings or ornamental designs to stone products would automatically reclassify them as artware, allowing them to benefit from lower tax rates.
What has changed
The authority ruled that the primary function of a product determines its tax rate. If a stone item is used for building or structural support, it is taxed as a building material, even if it is carved. This means businesses cannot use artistic work to lower the GST on essential construction components.
Who this affects
Stone manufacturers, interior designers, and construction material suppliers who produce carved or decorative stone products.
An example
A company manufactures carved marble pillars for a luxury hotel lobby. They previously charged 5% GST, believing the carving made the pillars 'art'. Under this ruling, the pillars are classified as structural building materials and must be taxed at the standard rate instead.
What you should do
Review your product catalog to see if your carved items serve a structural function. Remember that this ruling only applies to the company that asked for it; your local tax officer may still hold a different view on your specific products.
If you do nothing
If you apply a lower tax rate based on this ruling, your local tax officer may disagree with your classification. You could face a demand for the unpaid tax, along with interest and penalties for incorrect filing. Always consult with a professional before changing your tax treatment based on a ruling that does not directly name your business.
The terms explained
- Essential character test
- A method used by tax authorities to decide how to tax a product by looking at its main purpose rather than its appearance.
- Structural building elements
- Parts of a building that provide support or form the structure, such as pillars, wall panels, and load-bearing stone pieces.
- Artware
- Items created primarily for decoration or artistic display that do not serve a functional or structural role in a building.
The ruling in detail
Authority for Advance Ruling
M/s SKL DESIGN STUDIO PRIVATE LIMITED
RAJ/AAR/2026-27/02, dated 11.06.2026 · Rajasthan
Questions before the authority
- What is the correct classification of the Goods manufactured from Marble stone, Granites stone, sandstone, limestone, Slate, Mocha Cream, Pakur stone, travertine i.e. (i) Plain stone tiles with thickness from 10mm to 20mm. (ii) Plain stone tiles with custom thickness of 20mm to 160mm. (iii) Crafted stone panels and Pillars (iv) Wall claddings tiles (v) Decorative carved stone Art articles (vi) Statues (vii) Monuments
- What is the correct rate of GST on the above goods made from Marble stone, Granites stone, sandstone, limestone, Slate, Mocha Cream, Pakur stone, travertine? Kindly provide the relevant entry number of the schedule of the notification?
- Whether Stone Panels, Wall Claddings, Statues and Crafted Stone Articles having ornamental carving and artistic workmanship classified under 6802 is chargeable to GST at the rate of 5% under Notification No. 13/2025 dated 17.09.2025?
Facts
The applicant is engaged in providing architectural and interior design services, as well as the processing of natural stones like marble, granite, and sandstone. They manufacture various products including plain stone tiles, crafted stone panels, pillars, wall claddings, statues, and monuments. The applicant sought a ruling on the correct HSN classification and applicable GST rates for these items, arguing that items with ornamental carvings should qualify for a concessional 5% rate.
Ruling
| Question | What the authority ruled |
|---|---|
| Classification of stone products | Classified under HSN 6802 21 10, 6802 23 10, 6802 29 00, 6802 91 00, 6802 93 00, and 6802 99 00 based on material and degree of workmanship. Categorized by whether they are simply cut/sawn or worked beyond a flat surface. |
| Applicable GST rate | Standard rate for building/monumental stones; Concessional rate only for standalone ornamental items. Structural/building materials are excluded from the concessional rate. |
| Eligibility for 5% rate under Notif. 13/2025 | No for panels, wall claddings, and pillars; Yes for statues and standalone crafted stone articles. Eligibility depends on whether the item has an essential character of being purely ornamental. |
The authority ruled that structural building elements like stone panels, pillars, and wall claddings remain classified as building materials and are subject to the standard GST rate, regardless of artistic workmanship. Only standalone decorative items that serve no load-bearing or architectural function qualify for the concessional 5% rate under the cited notification. The ruling provides a detailed table mapping the applicant's goods to specific 8-digit HSN codes based on their degree of processing.
Reasoning
The authority applied the **essential character test** to determine that structural building elements do not lose their primary identity as building materials simply due to surface designs or carvings. It held that an exemption notification must be construed strictly and cannot be used to reclassify heavy architectural materials as artware. The decision relies on the **Customs Tariff Act, 1975** and the **CGST Act, 2017**, emphasizing that the primary utility of the product dictates its tax treatment. Consequently, items serving a load-bearing or architectural function are taxed at the standard rate, while only items with no such function qualify for the concessional rate.
Provisions relied on
- Section 97(2) of the CGST/RGST Act, 2017
- Section 100 of the CGST/RGST Act, 2017
- Rule 3(b) of the Customs Tariff Act, 1975
- Notification No. 13/2025-Central Tax (Rate) dated 17.09.2025
For the practitioner
This ruling clarifies that **ornamental carving does not automatically qualify** stone products for concessional GST rates if they retain a structural or architectural function. It helps practitioners distinguish between building materials and standalone artware for tax purposes. It does not, however, provide a blanket exemption for all carved stone products, reinforcing the need for a case-by-case assessment of the item's primary utility.
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-order_skl_design_studio_pvt_ltd_1_1.pdf
Legibility of the scan, as read: high.
Prepared 11-10-2026.
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