Tamil Nadu AAR Allows Withdrawal of Advance Ruling on GST Classification of Toys
The current appeal has been filed by a company named M/s. Stemplay Labs Private Limited (appellant) before the Tamil Nadu State Appellate Authority for Advance Ruling, Chennai, under Subsection (1) of Section 100 of the CGST Act 2017/TNGST Act 2017. The company has a registered address at First Floor, Door No. 4/20, Sivagamipuram, First Cross Street, Thiruvanmiyur, Chennai 600 041. The appellant is registered under GST, with GSTIN 33ABOCS4796B1Z2, with effect from January 20, 2025.
The company has proposed to start the manufacturing and supply of toy products for children in the age group between 3 and 10 years, mainly including plastic components with occasional use of materials such as magnets and rubber parts, such as rubber bands. The company claimed that their products attract a GST rate of 12% (6% CGST + 6% SGST) as they fall under 9503 0030 and are non-electronic in nature. Further asserted that similar toy products available online at e-commerce platforms like Amazon and Flipkart attract 12% GST. The company has also made payment of application fees of Rs. 5,000 each under subrule (1) of Rule 104 of the CGST Rules, 2017, and the SGST Rules, 2017. The company has sought an advance ruling, clearing some doubts regarding its business.
Questions Asked by Appellant:
The appellant, M/s. Stemplay Labs Private Limited, has asked the following questions, seeking the Tamil Nadu Advance Ruling No. 24/ARA/2025, dated July 14, 2025:
“Question 1: Classification of Goods and Tax Rate: What is the correct HSN Code and the applicable rate of tax under the Goods and Services Tax (GST) for the construction toys manufactured by our company, which are made primarily of plastic? Based on our understanding, the toys we intend to manufacture fall under Sl.No.228 of Chapler/Heading/Sub-Heading/Tariff/HSN Code 95030030 and are subject to a GST rate of 12%.
Question 2. Applicability of Notifications under the CGST and TNGST Acts: Please clarify the applicability of SI.No, Chapter/Heading/Subheading/Tariff item of the notifications issued under the provisions of the CGST Act/TNGST Act, 2017 for goods that are to be manufactured by us.”
What Did the Ruling Say?
In accordance with the Authority for Advance Ruling, Tamil Nadu No. 207, 2nd Floor, Papjm Building, No. 1, Greams Road, Chennai 600 006, the following answers have been given to the above questions:
The authority has disposed of the advance ruling filed by the company, considering the fact that the company had sent a letter dated 23.04.2025, wherein it requested to withdraw its application for advance ruling and requested the authority not to proceed further.
Citation: M/s. Stemplay Labs Private Limited (AAR Tamil Nadu); No. 24/ARA/2025; 14/07/2025
