Gst rate for HSN code 28530010

Distilled water used for batteries is correctly classified under HSN Code 28539010 (Distilled or conductivity water and water of similar purity). Although the broad 4-digit heading 2853 mentions "Compressed Air" in simplified text notifications, the full legal text explicitly covers distilled water. The applicable GST rate is 5% (2.5% CGST + 2.5% SGST).

The GST Department contends that the concessional GST rate of 5% under HSN 2853 is applicable only to Compressed Air, as specifically mentioned in the rate notification, and that all other goods falling under Chapter 28, including Distilled/DM Water, are taxable at 18%. In this regard, do you have any relevant notification, circular, or legal provision supporting the applicable GST rate on Distilled (De-mineralised) Water used for battery and industrial purposes.

The GST Department contends that the concessional GST rate of 5% under HSN 2853 is applicable only to Compressed Air, as specifically mentioned in the rate notification, and that all other goods falling under Chapter 28, including Distilled/DM Water, are taxable at 18%. In this regard, do you have any relevant notification, circular, or legal provision supporting the applicable GST rate on Distilled (De-mineralised) Water used for battery and industrial purposes.