Classification of Goods — Whether supply of Cryo Container (Liquid Notrogen Containers) is classifiable under HSN 7613 0019 or HSN 9617 0012 in the GST regime?”
The product (cryo containers) primarily serves dairy organizations, animal husbandries, cattle breeding farms, infertility clinics for semen preservation for artificial insemination / livestock breeding and serves pharmaceutical companies for storage of biological samples for medical research / vaccine preservation. Thus, these ‘cryo containers’ are meant primarily for preservation or storage of semen, biological samples etc. Though the ‘cryo containers’ can be utilized for small quantity transportation of Liquid Nitrogen, as mentioned in the brochure of the product, it cannot be said to be primarily used for transport or storage of compressed or liquefied gases.
As per the technical specifications of ‘cryo containers’ submitted by the applicant, it has double walls of aluminum, where the inner wall functions as inner vessel and outer wall functions as outer shell; Vacuum and Super insulation between inner vessel and outer vessel provides long term storage of liquid Nitrogen and such ‘cryo containers’ are capable to maintain the temperature as low as minus 196 degree Celsius.
Thus, the ‘cryo containers’ are vacuum vessels wherein vacuum and super insulation between inner vessel and outer vessel provides long term preservation or storage of semen, biological samples etc.
Ruling—The product ‘Cryo Container’ being supplied by M/s. Inox India Pvt. Ltd. (GSTIN 24AAACI4416P1ZH) is classifiable under Heading 9617.— Inox India Pvt. Ltd. - In Re - [2018] 2 TAXLOK.COM 102 (AAR-Gujarat)