The West Bengal Authority of Advance Ruling (AAR) has held that The HSN code for raincoat made of PVC sheet is 392620, so 18% Goods and Service Tax (GST) is payable on PVC raincoats.
The bench of Shafeeq S and Jaydip Kumar Chakrabarti has observed that once PVC raincoat is accepted as an article of apparel, it is beyond any doubt that it will be included under heading no. 392620 and not under heading no. 620140. There is no way that PVC Raincoats under sub-heading no. 392620 can be included under sub-heading no. 620140 since they are mutually exclusive. As such it will be taxable under entry no. 111 of Schedule III vide Notification No. 01/2017 – Central Tax (Rate) dated 28.06.2017, as amended.
The applicant, Ms. Waterproof Products Manufacturers & Traders Welfare Association, the applicant, is a Registered Association, bearing Registration No. SOO12038 of 2020-2021, consisting of members who are engaged in manufacturing and trading of various Waterproof Products.
The applicant has sought an advance ruling in respect of the Classification of Raincoat made of PVC Sheetings, which is worn by people during rain. The applicant has sought for an advance ruling on the HSN Code as well as GST Rate of Raincoat made of PVC Sheetings.
The applicant submitted that the Raincoats made up of PVC Sheeting would fall under Chapter 62 [Schedule – I] of Notification no. 1/2017 dated – Central Tax (Rate), dated 28th June, 2017 taxable at GST of 5%, if the sales price is less than INR 1000/- per piece and 12%, if the sales price exceeds INR 1000/- per piece. However, our members are evasive of the fact that the Department may raise a dispute in the near future and endeavor to classify the Raincoats made up of PVC Sheeting under some other head, probably, under HSN Code 392690, wherein GST is applicable at 18%.
The applicant submitted that Notification No.1/2017-Central Tax (Rate) New Delhi, the 28th June, 2017 prescribing the rate of GST clearly states that “Tariff item”, “sub-heading” “heading” and “Chapter” shall mean respectively a tariff item, sub-heading, heading and chapter as specified in the First Schedule to the Customs Tariff Act, 1975 (51 of 1975) and the rules for the interpretation of the First Schedule to the Customs Tariff Act, 1975 (51 of 1975), including the Section and Chapter Notes and the General Explanatory Notes of the First Schedule shall, so far as may be, apply to the interpretation of this notification i.e. GST Rate Notification.
The bench noted that there is a clear inclusion of raincoats made of sealing/sewing sheets of plastic in the Explanatory Notes to Chapter 39, which leaves no room for any doubt that the items in question are to be classified there appropriately. Therefore, the HSN code for raincoat made of PVC sheet is 392620. The GST tax rate on supply of PVC raincoat will be covered by Entry no. 111 of Schedule III and tax rate will be 9% CGST + 9% SGST.
Ruling Details
Applicant’s Name: Waterproof Products Manufacturers & Traders Welfare Association
Ruling Date: 22nd August, 2025
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