Gujarat AAAR Confirms Geomembrane Classification As Textile Product For Technical Use

The Gujarat Appellate Authority for Advance Ruling (GAAAR), in April 2026, upheld the classification of geomembranes under HSN 5911 as textile products for technical use, holding that the issue stood conclusively settled by the Gujarat High Court.

A Bench comprising SGST Member Arti Kanwar and CGST Member Sunil Kumar Mall, upheld Advance Ruling No. GUJ/GAAR/R/2022/46 dated 18 October 2022, and rejected the Revenue's challenge seeking classification of the product under HSN 3926 as an article of plastic. It observed:

“Since the jurisdictional High Court in the case of M/s Ananta Synthetic Innovations has held that the product in question is classifiable under Chapter 59 and not under Chapter 39, we are bound to follow the same.”

The respondent, Shree Ambica Geotex Pvt. Ltd., manufactures geomembranes from HDPE granules through a process involving extrusion of material into thin strips of less than 5 mm width, weaving them into fabric, and laminating both sides with LDPE/LLDPE, resulting in waterproof sheets used for lining aquaculture ponds and other technical applications.

The Deputy Commissioner, CGST, Division-IV, Ahmedabad South, had challenged the advance ruling, relying primarily on an earlier ruling in the case of Ananta Synthetic Innovations, where an identical product had been classified under Tariff Item 3926 90 99.

The Authority noted that the Ananta Synthetic Innovations ruling had been challenged before the Gujarat High Court, which allowed the writ petition and held that geomembranes are classifiable under Chapter 59 and not Chapter 39. It further recorded that no Special Leave Petition had been filed before the Supreme Court against the High Court judgment, thereby giving finality to the issue.

The Bench observed that since the jurisdictional High Court had already settled the classification, it was bound to follow the same, and further noted that the manufacturing process in the present case was identical to that in Ananta Synthetic Innovations, making the ruling directly applicable.

It also distinguished the precedents cited by the Appellant, including Harmony Plastics Pvt. Ltd., Rajasthan Synthetic Industries, and Gujarat Raffia Industries, holding that those decisions dealt with plastic fabrics, whereas the present case concerned fabric woven from strips or tapes.

Accordingly, the GAAAR rejected the appeal.