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West
Bengal Authority for Advance Ruling Goods and Service Tax
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Name
of the applicant
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Akansha Hair & Skin Care Herbal
Unit Pvt Ltd
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Address
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7
Bijoy Bose Road, Kolkata-700025
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GSTIN
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19AA
ECA3926G1ZQ
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Case
Number
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01
of 2018
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Date
of application
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January
17, 2018
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Date
of advance ruling
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April
09, 2018
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Applicant's
representative heard
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Sri
Anjan Dasgupta, Advocate
& Sri P K Mukherjee, Authorised Representative
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1. The
Applicant manufactures skin care preparations and wants an Advance Ruling
on the Classification of 33 of its products. The Applicant declares that
the question raised in this Application is not pending or decided in any
proceedings under the CGST / WBGST Act, 2017 (hereinafter the GST Act).
The officer concerned has not objected to the admission of the application.
As such, the question raised is admissible for Advance Ruling under section
97 (2) (a) of the GST Act. The Application is, therefore, admitted.
2. The
Applicant argues that its skin care preparations are Ayurvedic Medicaments. They are meant for therapeutic
or prophylactic uses, put up in packaging for retail sale and entirely correspond
to the description of goods under HSN 3004 [serial no. 63 of Notification
No. 1/2017-CT(Rate) dated 28/06/2017], and, therefore, taxable under Schedule
II.
3. The
Applicant has submitted a list of these 33 manufactured products and their
description as per the product label for review in Annexure X of their submission,
which is given below:
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Name of the product
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Nature of the product
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Description
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Baranga
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Face
& Body Grain
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Brightens the skin all the more without
black heads, pimples and scars
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Tanuruchi
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Face
Pack for Oily Skin
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Control
excessive oil secretion and takes care of scar free face
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Twakamadhuri
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Face
Pack for Normal & Dry Skin
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Keeps skin
glossy without freckles and spots
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Subarna
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Face
Wash for Oily Skin
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Removes
dead cells and black heads for oily skin
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Angarag
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Black
Patch Pack
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Beautifies
the skin of sun-burn and black patches, ensures dazzling liveliness. Enhances
glamour and beauty
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Rupam
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Pimple
Pack
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Glossy skin
without pimples and rashes
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Tanurima
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Baby
Skin Care
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Fair and
glossy skin for your baby
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Romancho (lavender)
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Body
Talc
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Soothing
agent having anti-bacterial, anti-fungal anti-septic activity. Prevents
excessive perspiration. Feeling of freshness, increases lustre of skin, gives relief from itching sensation
and irritation of prickly heat, very helpful remedy in summer boils and
pimples.
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Romancho (Vanilla)
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Body
Talc
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Soothing
agent having anti-bacterial, anti-fungal anti-septic activity. Prevents
excessive perspiration. Feeling of freshness, increases lustre of skin, gives relief from itching sensation
and irritation of prickly heat, very helpful remedy in summer boils and
pimples.
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Romancho (Kewra)
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Body
Talc
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Soothing
agent having anti-bacterial, anti-fungal anti-septic activity. Prevents
excessive perspiration. Feeling of freshness, increases lustre of skin, gives relief from itching sensation
and irritation of prickly heat, very helpful remedy in summer boils and
pimples.
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Swarnabho
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Skin
Polishing and fairness oil
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Keeps skin
soft, fair, glowing, stops pre-mature ageing and wrinkling of skin, prevents
sun burn rashes, dryness, discolouration and
burning sensation of skin. Also helps growing of your baby.
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Komal Shree
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Growing
& Skin Glowing oil for baby
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Keeps skin
soft, fair, glowing, stops pre-mature ageing and wrinkling of skin, prevents
sun burn rashes, dryness, discolouration and
burning sensation of skin. Also helps growing of your baby.
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Nabaroop (Aloe Vera and Chandan)
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Face
& Body Wash
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Properly
cleanses, exfoliate and moisturizes the skin. Helps for removing make-ups
and sunscreen which, clog pores. Strengthens the natural protection of
the skin. Instantly enhances glow and fairness. Improves the skin texture
of skin and body
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Nabaroop (Rose and Cucumber)
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Face
& Body Wash
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Properly
cleanses, exfoliate and moisturizes the skin. Helps for removing make-ups
and sunscreen which, clog pores. Strengthens the natural protection of
the skin. Instantly enhances glow and fairness. Improves the skin texture
of skin and body
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Nabaroop (Lemon)
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Face
& Body Wash
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Properly
cleanses, exfoliate and moisturizes the skin. Helps for removing make-ups
and sunscreen which, clog pores. Strengthens the natural protection of
the skin. Instantly enhances glow and fairness. Improves the skin texture
of skin and body
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Nabaroop (Neem)
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Face
& Body Wash
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Properly
cleanses, exfoliate and moisturizes the skin. Helps for removing make-ups
and sunscreen which, clog pores. Strengthens the natural protection of
the skin. Instantly enhances glow and fairness. Improves the skin texture
of skin and body
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Nabaroop (Orange)
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Face
& Body Wash
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Properly
cleanses, exfoliate and moisturizes the skin. Helps for removing make-ups
and sunscreen which, clog pores. Strengthens the natural protection of
the skin. Instantly enhances glow and fairness. Improves the skin texture
of skin and body
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Swarnali
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Fairness
Cream
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Improve
the skin complexion. Removes acne, pimples, black spot, black heads, hyper pigmentation. Make the skin glossy and shiny
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Tanujjal
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Fairness
Face and Body Scrubber
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Gently scrubs
away skin scars, white & black heads, dead cells, makes skin smooth,
healthy and glowing
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Twaka Snigdha
(Lemon)
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Skin
Toner
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Helps in
the normal firming and toning of skin along with hydrating the skin to
make it glow, fresh and smooth. Helps to skin and tighten skin pores.
Make skin soft and more elastic, reduces skin oilyness.
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Twaka Snigdha
(Orange)
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Skin
Toner
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Helps in
the normal firming and toning of skin along with hydrating the skin to
make it glow, fresh and smooth. Helps to skin and tighten skin pores.
Make skin soft and more elastic, reduces skin oilyness.
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Twaka Snigdha
(Neem)
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Skin
Toner
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Helps in
the normal firming and toning of skin along with hydrating the skin to
make it glow, fresh and smooth. Helps to skin and tighten skin pores.
Make skin soft and more elastic, reduces skin oilyness.
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Twaka Snigdha
(Rose)
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Skin
Toner
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helps in the normal firming and toning of skin
along with hydrating the skin to make it glow, fresh and smooth. Helps
to skin and tighten skin pores. Make skin soft and more elastic, reduces
skin oilyness.
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Sukhparash
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Face
& Body Cream
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Prevents
from pimples, blemishes and skin rashes. Helps to cure minor and sunburn
quantity
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Namrata
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Moisturizer
for normal to dry skin
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Helps to
moisturize, soften and hydrate the skin. Prevents skin from rashes and
burning sensation
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Pailab
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Anti-Crack
cream
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antibacterial
& anti-septic for removal of cracked feet
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Aadrita
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Moisturizer
for Oily skin
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helps to moisturize, soften and hydrate the skin.
Prevents the skin from rashes and burning sensation
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Komal Parash
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Baby
Body Talc
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Soothing
agent having anti-bacterial, anti-fungal anti-septic activity. Prevents
excessive perspiration. Feeling of freshness, increases lustre of skin, gives relief from itching sensation
and irritation of prickly heat, very helpful remedy in summer boils and
pimples.
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Tanutra
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Sun
& Pollution Protection Base
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protects
skin from scorching sun and environmental pollution and hazards of heavy
make-up
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Tanumitra 40
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Sunscreen
Cream
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Protects
from sun-burn injury.
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Tanumitra 60
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Sunscreen
Cream
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Protects
from sun-burn injury.
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Swarnajyoti
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Face
Wash
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Removes
skin impurities, black heads, dead skin cells, pimples and scars
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Sunayana
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Dark
Circle reducing cream
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Reduces
dark circles and puffiness of the skin around the eyes. Softens fine lines
and removes wrinkles
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4. The
Applicant refers to the ruling of the Authority for Advance Ruling, Central
Excise, Customs & Service Tax, New Delhi (hereinafter the AAR) [2009
(248) ELT 932 (AAR)] in the matter of M/s Guthy
Renker Marketing Pvt
Ltd. The petitioner therein was the Indian subsidiary of a Mauritius based
company and intended to import revitalising toner,
repairing lotion, cleanser, and refining mask of 'Proactive' brand. According
to the petitioner, the cleanser and the repairing lotion contain almost
2.5% Benzoyl Peroxide as an ingredient, which has immense potential to cure
acne. The fourth product, namely the mask, contains 6% sulphur as an ingredient, which too has therapeutic
value. The first product, namely the toner, does not contain any active
ingredient for curing the disease but is used for cleansing the skin as
an aid to acne treatment. The petitioner sought an Advance Ruling on commodity
Classification. After that, the AAR refers to several decisions of the Apex
Court that have laid down common parlance as the appropriate test for determining
the meaning or connotation of words or expressions describing an article
in a Tariff Schedule. According to the AAR, common parlance test is not
a rigid formula capable of being applied in all situations. The test ceases
to be applicable if the products referred to are couched in technical/scientific
language, or there is a definite indication in the Tariff Schedule negating
application of this standard test.
5. The
AAR also points out that most of the skin care or toilet preparations containing
some recognized medical ingredients and professing to cure or mitigate the
skin diseases for which drug licenses have been obtained are held by the
apex court as medicaments notwithstanding the fact that they have cosmetic
value too (for example, prickly heat powder, anti-dandruff shampoo, anti-pimple
herbal powder etc.). If the product can be used for the treatment of specific
ailments and the ingredients used are those specified in the medical or
pharmacology books, a strong case exists for it being classified as a medicament.
6. There
is an apparent contradiction between Note 1 to Chapter 30 and the language
of the heading 3304 in excluding medicaments from the skin care products
falling there under. The AAR resolves the contradiction by retaining in
3304 such skin care preparations as having only incidental or subsidiary
therapeutic or prophylactic value. Other skin care preparations having substantial
therapeutic or prophylactic use should be treated as medicaments under heading
3004. In other words, it is not sufficient that a skin care preparation
incidentally or in a small way helps in controlling skin disease. Its curative
or preventive value must be substantial, and the product must be manufactured
primarily to control or cure a skin-related disease. That is to say, if
preparations for the care of skin contain sufficient medical ingredients
to offer a cure for skin ailments, they stand excluded from the purview
of 3304.
7. While
discussing Note 1 to Chapter 30 in Puma Ayurvedic
Herbal Pvt Ltd (supra) the Supreme Court observes,
"Thus preparations falling in Chapter 33 even if they have therapeutic
or prophylactic properties will not fall under Chapter 30 which deals with
pharmaceutical products. The reason for this appears to be that even cosmetics
may have something to improve skin or other parts of the body where they
are used. In that sense, they may have some therapeutic value, yet they
remain cosmetic." The Supreme Court further observes that preparations
falling under heading 3304 are primarily beauty or makeup preparations.
They may incidentally help in protection against skin irritants. They may
help as a skin tonic, yet they are cosmetics because skin protection is
a subsidiary benefit.
8. The
AAR, therefore, concludes that the test to be applied for determining whether
the goods which fall broadly within the description of skin care preparations
are to be classified as medicaments is whether they are intended primarily
for use in the treatment of skin disorder or diseases and whether the ingredients
therein have sufficient therapeutic value. If the potential of a product
as a medicament to cure any skin ailments is not clear or is not established,
it cannot be placed under Chapter 30 as a Medicament.
9. The
AAR's observations are primarily based on Puma Ayurvedic
Herbal Pvt Ltd [2006 (196) ELT 3 (SC)]. In its
written submission the Applicant also refers extensively to the above judgment,
which has traversed the history of Supreme Court's observations on the related
questions and issues while deciding upon the classification of the petitioner's
skin care products. It has direct relevance to the Applicant's case and
needs to be discussed in some detail for clarity on the legal position regarding
classification of goods in the present context.
10.
In Puma Ayurvedic Herbal Pvt
Ltd (supra) the Court observes, "In order to determine whether a product
is a cosmetic or a medicament a twin test has found favour
with the Courts. The test has the approval of this Court also vide Collector
Vs. Richardson Hindustan Ltd [1989(42) ELT A100 (SC)/2004 (9) SCC 156].
There is no dispute about this as even the Revenue accepts that the test
is determinative for the issue involved. The tests are I. Whether the item
is commonly understood as a medicament which is called the common parlance
test (emphasis added). For this test, it will have to be seen whether in
common parlance the item is accepted as a medicament. If a product falls
into the category of medicament, it will not be an item of common use (emphasis
added). A user will use it only for treating a particular ailment and will
stop its use after the ailment is cured. The approach of the consumer towards
the product is very material. One may buy any of the ordinary soaps available
in the market. But if one has a skin problem, he may have to buy a medicated
soap. Such soap will not be an ordinary cosmetic. It will be medicament
falling in Chapter 30 of the Tariff Act.
II Are
the ingredients used in the product mentioned in the authoritative textbooks
on Ayurveda? What is to be seen is whether the products are likely to be
in common use by normal consumers. Common parlance meaning and understanding
is a strong factor in the determination of the classification of products.
One need not resort to the scientific or technical meaning of the terms
used (emphasis added). So far as the other test is concerned, the learned
counsel for the appellant has placed on record material from the Ayurvedic texts or Pharmacopoeia in support of each
product which is the subject matter of the present appeal to show that the
ingredients of each product are independently mentioned in the Ayurvedic texts."
11.
In Puma Ayurvedic Herbal Pvt
Ltd (supra) the Appellant had a license to manufacture Ayurvedic products obtained from the Drug Controller
under the Drugs and Cosmetics Act, 1940. All the items under appeal before
the Supreme Court were produced from ingredients found in Ayurveda textbooks.
They are manufactured as per the Ayurveda pharmacopoeia and had curative,
therapeutic or prophylactic value. They were meant to give relief from body
ailments. As such, all ingredients were Ayurvedic
raw material. Besides this, the evidence produced by the appellant before
the authorities in the shape of letters from consumers, from doctors and
from Ayurvedic physicians, according to the Apex
Court, satisfied the common parlance test. The Court refers to Richardson
Hindustan Ltd. [1989 (42) ELT A100], where the court has held that the articles
enumerated in the tariff schedules must be construed as far as possible
in their ordinary or popular sense, that is, how the common man and persons
dealing with it understand it (emphasis added). If the customers and the practitioners
in Ayurvedic medicine, the dealers and the licensing
officials treat the products in question as Ayurvedic
medicines that fact gives an indication that they are exclusively Ayurvedic medicines or that they are used in the Ayurvedic system of medicine. This is especially so
when all the ingredients used are mentioned in the authoritative books on
Ayurveda. From the above and other judgments, the Apex Court observes that
the law is settled on the applicability of the twin test for determination
of the classification of a product (emphasis added).
12.
In its judgment dated 13/04/2009 in Baidynath
Ayurved Bhawan Ltd (CA
No. 4048 of 2001), the Apex Court revisited the question of the twin test
for determining whether the product is an Ayurvedic
Medicament or not. It observes that the twin test noticed in Puma Ayurvedic Herbal (P) Ltd continue to be relevant. The
court holds that classification should be based on the popular meaning and
understanding attached to such products by those using them and not the
scientific and technical meaning of the terms and expressions used (emphasis
added). "The approach of the consumer or user towards the product,
thus, assumes significance. What is important to be seen is how the consumer
looks at a product and what is his perception in respect
of such product. The user's understanding is a strong factor in the
determination of the classification of the products."
13.
In the light of the above discussion, we should now find out what are parameters
and their relative importance in deciding whether a product should fall
under subhead 3004 as an Ayurvedic Medicament
or be classified as a skin care preparation (other than medicaments) under
subhead 3304. Medicaments are not defined under the GST Act or in the First
Schedule of the Customs Tariff Act, 1975 (hereinafter the Tariff Act), with
which the GST Act has been aligned for the purpose of classification. The
methods settled by the apex court for determining whether a product is to
be classified as medicaments for fixing the tariff should be followed as
the only lawful course. The Apex Court has settled for a twin test method.
It means how the product is understood in common parlance and whether the
product has been manufactured using ingredients and formula provided in
the authoritative textbooks of Ayurveda are the two parameters for such
classification. Other parameters like classification in the license issued
by the competent authority are relevant only in relation to and subject
to the twin tests discussed above. It may be mentioned in this connection
that different parameters can be used based on the purpose for the classification.
The Apex Court has long settled that classification for fixing tariff should
be based on how the goods are understood in common parlance in the commercial
world.
14.
In subhead 3004 the emphasis is on therapeutic or prophylactic uses. Even
if a product is manufactured using ingredients and according to the formula
prescribed in the authoritative textbooks of Ayurveda, it should not be
classified as a medicament under heading 3004 unless it is meant for therapeutic
or prophylactic uses. In other words, it is not sufficient that a skin care
preparation, manufactured following a formula in an authoritative textbook
of Ayurveda, helps in controlling skin disease. Its curative or preventive
value must be substantial, and the product must be manufactured primarily
to control or cure a skin-related disease, and the consumers use it primarily
for treatment, mitigation, cure or prevention of specific skin disease or
skin disorder.
15.
Note 1 (e) to Chapter 30 states that the Chapter does not cover preparations
of headings 3303 to 3307, even if they have therapeutic or prophylactic
properties. In the present context, it means a skin care preparations, if
it otherwise falls under heading 3304, shall be excluded from Chapter 30,
even if it has therapeutic or prophylactic properties. But what should be
the yardstick to determine whether a product qualifies to be included under
heading 3304?
16.
The discussion in Puma Ayurvedic Herbal Pvt Ltd (supra) is relevant. The apex court says, "The
learned counsel for the respondent drew our attention to Note 2 of Chapter
33 of the Central Excise Tariff which is as under: 'Note 2. Heading Nos.33.03
to 33.07 apply, inter alia, to products, whether or not mixed (other thanaqueous distillates and aqueous solutions of essential
oils), suitable for use as goods of these headings and put up in packings
with labels literature or other indications that they are for use as cosmetics
or toilet preparations or put up in a form clearly specialized to such use
and includes products whether or not they contain subsidiary pharmaceutical
or antiseptic constituents, or are held out as having subsidiary curative
or prophylactic value.' On the basis of this Note it was argued that even
if a product has some curative or
prophylactic value, it will still be cosmetic.
We cannot accept this argument. The learned counsel has overlooked the use
of the word 'subsidiary' in the said note from which it follows that a subsidiary
curative or prophylactic use will not convert a cosmetic into a medicament.
We have tried to illustrate this by giving the example of a bald man treating
his baldness by use of the Ayurvedic product.
The curative use of the product is primary in that example and not subsidiary.
The subsidiary result is an improvement in appearance. Therefore, in our
view, Note 2 to Chapter 33 does not help the respondent. Rather Note 5 to
the said Chapter, makes it clear that the products which fall under heading
33.04 are primarily beauty or make up preparations. They may incidentally
help in protection against skin irritants. They may also help as a skin
tonic, yet they are cosmetics because skin protection is a subsidiary benefit."
17.
The above judgment of the Apex Court is based on specific Notes to Chapter
33 of the Excise Tariff Act, 1985. Applicability of the apex court's observations
in the present context is, therefore, subject to the Notes and entries in
the Tariff Act, as it stands today after the GST Act comes into effect.
Note 2 to Chapter 33 of the Tariff Act is completely rephrased. Note 3 to
Chapter 33 of the Tariff Act now stands as under: "Heading Nos.33.03
to 33.07 apply, inter alia, to products, whether or not mixed (other than
aqueous distillates and aqueous solutions of essential oils), suitable for
use as goods of these headings and put up in packings of a kind sold by
retail for such use." Note 5 to Chapter 33 of the Tariff Act does not
exist anymore. It, therefore, appears that the phrase 'suitable for use
as goods of these headings and put up in packings with labels literature
or other indications that they are for use as cosmetics or toilet preparations
(emphasis added) or put up in a form clearly specialized to such use and
includes products whether or not they contain subsidiary pharmaceutical
or antiseptic constituents, or are held out as having subsidiary (emphasis
added) curative or prophylactic value' in Note 2 to Chapter 33 and also
the Note 5 do not exist for the purpose of the GST Act.
18.
Conclusions reached in Puma Ayurvedic Herbal Pvt Ltd (supra) and followed by the AAR in M/s Guthy Renker Marketing Pvt Ltd [2009 (248) ELT 932 (AAR)], based on earlier
constructions of Notes 2 and 5 to Chapter 33 in the Excise Tariff Act, 1985
are, therefore, need to be revisited in the context of the GST Act. In theabsence of the restrictive phrases attributed to
Notes 2 and 5 to Chapter 33, heading 3304 should now include all preparations
for the care of skin, whether cosmetics or not or having therapeutic or
prophylactic properties of whatever degree, excluding the ones that are
medicaments covered by Chapter 30. A
preparation for care of skin, unless already
specified under heading 3304, should, therefore, first be examined concerning
its suitability for inclusion as a medicament in heading 3004 by applying
the twin tests set out in Puma Ayurvedic Herbal
Pvt Ltd (supra) and Baidynath
Ayurved Bhawan Ltd (supra).
If it fails the test, it should be classified under heading 3304. On the other hand,
if the skincare preparation is specifically included under heading 3304
(for example sunscreen or suntan preparations, talcum powder, face powder,
moisturizing lotion etc.), it is not to be classified as a medicament under
heading 3004 in terms of Note 1(e) to Chapter 30, even if it has therapeutic
or prophylactic properties of whatever degree.
19.
It is acknowledged that nearly all proper skin care preparations have therapeutic
or prophylactic properties, as they help in maintaining or improving the
health of the skin. On the other hand, skin care preparations that are used
as medicaments may have the effect of enhancing appearance and beauty by
restoring skin health. The essential difference, therefore, lies in the
user's perception of a particular product. If the user consumes the product
primarily for cure from or treatment or mitigation of or for prevention
of a specific skin disease or disorder, it should be treated as a medicament
classifiable under heading 3004 (unless, of course, it has been specifically
included under heading 3304). The effect of enhancing appearance of the
skin or beauty is not what the product is offered for or used by the consumer.
20.
In the context of the present application, there is no dispute that the
products are manufactured under valid drug license and following the formula
prescribed in the authoritative textbooks of Ayurveda. A few ingredients
may have been added for preservation of the quality of the product, which,
as settled by the apex court on several occasions, should not be considered
material while ascertaining the underlying Ayurvedic
nature of the product. The Applicant has also furnished various documents
for facilitating the common parlance test. They include photocopies of prescriptions
indicating that several products are being prescribed by the medical practitioners.
A CD containing video and also the English transcript of a popular TV programme where consumers are describing their experience
in using a few of the products, is also submitted. Finally, the Applicant
has submitted the labels containing a description and use of the products
and physical samples.
21.
The label contains indication and method of use for each of the products.
They are compared with the indication as per the list provided in the application.
The prescriptions and also information available in the English Transcript
are taken into account wherever relevant, subject to the limitation that
the CD contains only snippets of different episodes of a TV show where the
users are uniformly endorsing the Applicant's products as showing good results.
It is not clear whether the 'good results' relate to enhancing appearance
of the skin or treatment of a disease. We are not to involve ourselves in
examining efficacy of the Applicant's products. Our focus will be to ascertain
from available materials what the Applicant is offering and consumer is
using. A more objective way to examine it is to analyse
the information contained in the labels attached to the product when offered
in retail set up. The information provided on the labels may be considered
as written communication from the manufacturer to the consumer as to what
is being offered. If a customer purchases the product it may be presumed
that he or she accepts the offer and believes in the information contained
in the label.
22.
In response to an enquiry made regarding the products in communication dated
03.04.2018 the Applicant has stated that three (03) of the products in the
list submitted by the Applicant, namely, Swarnajyoti,
Sunayana and Tarumitra-60, are yet to be manufactured
by them and are presently not in existence. This was also admitted by the
Applicant during Personal Hearing on 04.04.2018.
23.
In light of the above discussion, it appears only the products, Rupam (Pimple pack) and Pailab
(Anti-crack cream) of the list of their products are offered for treatment
or prevention of specific skin disorders. The products, namely, Swarnajyoti, Sunayana and
Tarumitra-60 have not yet come into existence, and, therefore, excluded
from the ambit of examination for the purpose of this ruling. The other
products are either already specified under heading 3304 (like talcum powder,
sunscreen, moisturising lotion etc.) and, therefore,
cannot be considered for inclusion under heading 3004. The remaining products
mentioned in the list submitted by them are not offered primarily as medicaments
and, therefore, not to be included under heading 3004.
In view
of the foregoing we rule as under
RULING
1. Preparations
for the care of the skin namely, Rupam (Pimple
Pack) and Pailab (Anti-Crack Cream), in the list
submitted by the Applicant of the Application are classifiable as Medicament
under heading 3004 of the Customs Tariff Act, 1975. Preparations listed
as Swarnajyoti, Sunayana
and Tarumitra-60 have not yet come into existence, and, therefore, no rulings
are pronounced on their classification. The remaining products mentioned
in the list submitted by them are not offered primarily as medicaments and,
therefore, not to be included under heading 3004.
This
ruling is valid subject to the provisions under Section 103(2) until and
unless declared void under Section 104(1) of the GST Act.
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(VISHWANATH)
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(PARTHASARATHI
DEY)
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Member
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Member
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West
Bengal Advance Ruling Authority
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West
Bengal Advance Ruling Authority
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