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GST Classification and Rate on Marble, Granite and Other Processed Stone Products – Rajasthan AAR

Advance Ruling No. RAJ/AAR/2026-27/02

Applicant: M/s SKL Design Studio Private Limited, Jaipur, Rajasthan
Authority: Rajasthan Authority for Advance Ruling, GST

Introduction

The Rajasthan Authority for Advance Ruling has examined the GST classification and applicable rate of tax on various products manufactured from natural stones such as marble, granite, sandstone, limestone, slate, Mocha Cream, Pakur stone and travertine.

The applicant, M/s SKL Design Studio Private Limited, is engaged in architectural and interior design services as well as designing and processing natural stones. The applicant manufactures a variety of stone products, including plain stone tiles, crafted stone panels, pillars, wall claddings, decorative carved stone articles, statues and monuments.

The main dispute before the Authority was whether products having additional carving, artistic workmanship or customised thickness could qualify for the concessional GST rate applicable to ornamental stone articles, or whether they would continue to be treated as building/architectural stones liable to the standard rate.

Background of the Case

M/s SKL Design Studio Private Limited, Jaipur, purchases natural stone blocks and undertakes several processes such as:

• Cutting and sizing;
• Edge cutting;
• Surface finishing;
• Polishing;
• Pietra dura and inlay work;
• Hand sculpting;
• Digital sculpting;
• Relief work;
• 3D effects;
• Machine work; and
• Other manual and mechanical processing.

The applicant manufactures different categories of products from these stones.

Plain Stone Tiles

Stone blocks and slabs are mechanically cut into square or rectangular shapes with specified thickness. These tiles may also undergo polishing or surface finishing and are generally used for flooring and walls.

Crafted Stone Panels and Pillars

Natural stone blocks or slabs are processed into customised thicknesses, generally ranging from 30 mm to 160 mm, and subjected to carving, relief work and other decorative processes.

These products may be used for architectural decoration, monuments, landscaping and interior or exterior applications, including wall claddings, pedestals and fountains.

Statues and Decorative Stone Articles

The applicant also manufactures three-dimensional stone products through carving, sculpting, engraving and chiselling, including idols, monuments and other decorative articles.

Questions Raised Before the AAR

The applicant sought a ruling on three principal questions:

1.    What is the correct classification and eight-digit HSN code for plain stone tiles, customised stone tiles, crafted stone panels and pillars, wall cladding tiles, decorative carved stone articles, statues and monuments?

2.    What is the applicable GST rate on these products?

3.    Whether stone panels, wall claddings, statues and crafted stone articles having ornamental carving and artistic workmanship, classified under Heading 6802, are eligible for the concessional 5% GST rate under Notification No. 13/2025-Central Tax (Rate) dated 17.09.2025?

Applicant's Contention

The applicant submitted that the products broadly fall under HSN 6802, covering worked monumental or building stone and articles thereof, including ornamental stone articles, statues, statuettes and decorative articles of stone.

The applicant's principal contention was that the nature and degree of workmanship should be considered while determining the applicable GST rate.

According to the applicant:

• Plain stone tiles up to 20 mm should attract 18% GST.
• Thicker customised stone tiles between 30 mm and 160 mm could qualify as ornamental stone articles and attract 5% GST.
• Crafted stone panels, pillars, wall claddings, statues and decorative carved stone articles having ornamental workmanship should also qualify for the concessional 5% rate under Notification No. 13/2025-Central Tax (Rate).

The applicant therefore argued that different GST rates could apply within the same HSN depending upon the nature of the product, its use and the degree of workmanship.

Findings of the Rajasthan AAR

1. All Products Cannot Be Covered Under One Eight-Digit HSN

The Authority held that although the products broadly fall under Chapter Heading 6802, it is not possible to assign a single eight-digit HSN code to the applicant's entire range of products.

The precise classification depends upon factors including:

• The geological nature of the stone;
• The raw material used;
• The degree of processing; and
• The nature of workmanship.

The Authority specifically observed that classification at the six-digit and eight-digit level has to be determined on a case-by-case basis.

Classification Under HSN 6802

The Authority broadly classified the products as follows:

The Authority also mapped products such as plain tiles, wall claddings, crafted panels, pillars, decorative carved articles, statues and monuments according to the nature of the stone and the degree of workmanship.

2. Thickness Alone Does Not Change the Classification

An important observation of the Authority was that merely increasing the thickness of a stone product does not convert a building material into an ornamental article.

Similarly, merely providing carving or artistic finishing does not automatically result in eligibility for the concessional rate.

The Authority observed that classification depends upon the essential character and primary utility of the goods, rather than merely their physical dimensions or aesthetic features.

For example, a thick stone slab used for flooring continues to be a building material. Likewise, a carved stone pillar used as a structural or architectural element does not become an ornamental article merely because artistic workmanship has been applied to it.

3. Essential Character Test

The Authority applied the principle of essential character for determining the applicable GST treatment.

It observed that:

Structural and architectural products continue to retain their identity as building materials even when they contain artistic designs or customised workmanship.

Accordingly:

• Plain stone tiles remain building materials.
• Thick customised tiles remain building materials where their primary use is structural or architectural.
• Stone panels and pillars used in construction remain architectural/building materials.
• Wall claddings remain architectural products.
• Standalone statues and purely decorative articles may qualify as ornamental articles where they have no structural or architectural function.

4. GST Rate – 18% for Building and Architectural Stone Products

The Authority held that products whose essential character is structural or architectural are liable to the standard GST rate applicable to Chapter Heading 6802.

The ruling specifically treats the following as building/architectural products:

• Plain stone tiles;
• Customised thickness stone tiles;
• Crafted stone panels;
• Pillars;
• Wall claddings; and
• Monuments having structural or architectural utility.

These products are therefore subject to the standard rate, stated in the ruling as 18%.

5. Concessional 5% Rate for Genuine Ornamental Articles

The applicant relied upon Notification No. 13/2025-Central Tax (Rate) dated 17.09.2025 to claim the concessional rate for products having ornamental carving and artistic workmanship.

The Authority, however, clarified that the concessional rate cannot be extended merely because a building material contains artistic designs, carvings or relief work.

The 5% concessional treatment is available to genuine standalone decorative or ornamental articles, such as statues, where their essential character is purely ornamental and they do not have a structural, load-bearing, flooring or architectural function.

6. Stone Panels, Wall Claddings and Pillars

The Authority specifically rejected the claim that stone panels, wall claddings and pillars would qualify for 5% GST merely because they contain ornamental carving or artistic workmanship.

Where these products are integrated into a building or have an architectural or structural function, they continue to be treated as building stones.

Therefore, they are not eligible for the concessional 5% rate merely on account of artistic workmanship.

7. Statues and Standalone Decorative Articles

The position is different in the case of standalone statues and decorative stone articles.

Where the article is:

• Standalone;
• Purely ornamental;
• Not load-bearing;
• Not used for flooring; and
• Not an architectural component,

it can qualify for the concessional treatment prescribed for ornamental articles under Notification No. 13/2025-Central Tax (Rate).

The Authority specifically recognised standalone statues as falling within the category of products eligible for the concessional treatment where the required conditions are satisfied.

Final Ruling

The Rajasthan Authority for Advance Ruling held that the classification and GST rate are to be determined based on the nature of the stone, degree of workmanship and essential character/primary utility of the finished product.

Classification

Products under consideration broadly fall under Heading 6802, but the precise eight-digit HSN depends upon the type of stone and the degree of processing/workmanship. A single eight-digit HSN cannot be applied to the applicant's entire product range.

GST Rate

Products having a structural, architectural or building-material character are subject to the standard rate applicable to such products, stated in the ruling as 18%.

Concessional Rate

The 5% concessional rate under Notification No. 13/2025-Central Tax (Rate) is available only to qualifying standalone ornamental/decorative articles, and not to structural or architectural stone products merely because they contain artistic carving or decorative workmanship.

Conclusion:

The Rajasthan AAR ruling in M/s SKL Design Studio Private Limited provides important guidance for businesses dealing in processed marble, granite and other natural stone products.

The key principle emerging from the ruling is that the essential character and primary utility of the finished product are more important than its thickness, customised design or artistic workmanship.

Thus, a stone product does not become an ornamental article merely because it has been carved, polished or customised. Where the product continues to serve a building, flooring, structural or architectural purpose, it remains classifiable as a building/monumental stone product and is liable to the applicable standard rate.

On the other hand, where the product is a standalone decorative article with purely ornamental character and no structural or architectural function, the concessional rate prescribed for ornamental articles may be available, subject to the conditions of the relevant notification.

Disclaimer: All the Information is based on the notification, circular advisory and order issued by the Govt. authority and judgement delivered by the court or the authority information is strictly for educational purposes and on the basis of our best understanding of laws & not binding on anyone.