Woven Pyjama Set is HSN 620721; 5% GST Rate Applies if Per-Set Price is Below ₹1,000.

Issue

What is the correct HSN classification and applicable GST rate for woven men’s pyjama sets sold in a multi-set pack, where the pack value is over ₹1,000 but the per-set value is under ₹1,000?

Facts

The applicant, a textiles exporter, supplies men’s woven pyjama sets (67% cotton blend).
The sets are packed as two sets per pack per the overseas buyer’s instructions.
The total value of one pack (containing two sets) is ₹1,371.
This means the value of a single pyjama set is ₹686, which is below the ₹1,000 threshold for apparel.
The applicant was previously paying 12% IGST and sought a ruling on the correct HSN and whether the 5% rate should apply.

Decision (Ruling of the AAR)

The Authority for Advance Ruling (AAR) ruled in favour of the applicant on both counts:

Classification: The AAR held that since the garments are woven and predominantly of cotton, the correct classification is HSN 620721 (men’s or boys’ nightshirts and pyjamas, of cotton).
GST Rate: The AAR ruled that the applicable GST rate is 5%.
- It clarified that the term “piece” in the apparel rate notification refers to a single, independently usable item, which in this case is one pyjama set (one shirt and one pant).
- The GST rate threshold of ₹1,000 must be applied to the value of this single “piece” (the set), not the total value of the multi-set pack.
- Since the per-set price (₹686) is below ₹1,000, the 5% rate under Sl. No. 223 of Schedule I of Notification No. 01/2017-Central Tax (Rate) applies.

Key Takeaways

HSN Classification: Woven, cotton-based men’s pyjama sets are classified under HSN 620721.
“Per Piece” vs. “Per Pack”: The ₹1,000 GST rate threshold for apparel applies to the value of the individual unit (one set), not the value of the bulk package it is sold in.
Valuation Principle: A pyjama set (top and bottom) is treated as one “piece” for the purpose of this valuation threshold, as it is a single, independently usable apparel item.

AUTHORITY FOR ADVANCE RULING, TAMILNADU

Link up Textiles (P.) Ltd., In re

C. Thiyagarajan and B. Suseel Kumar, Member

TN/42/AAR/2025

OCTOBER 8, 2025

PROCEEDINGS

1. M/s. Link Up Textiles private limited, 6AB-7AB, Sri Devi Kuppum Main Road, Kumaran Colony, Valasaravakkam, Chennai-600087. Tamil Nadu having GSTIN 33AAACL1248E122, registered under the goods and services Tax Act, 2017. They have filed this application for advance ruling under Section 97 of the CGST Act, 2017, and corresponding provisions under the Section 97 of TNGST Act. The Applicant has made a payment of application fees of Rs. 5,000/- each under sub rule (1) of Rule 104 of CGST Rules, 2017 and SGST Rules, 2017.

2. The applicant are exporting Men’s Pyjama Set consisting of a top (Kurta/Shirt) and bottom (pyjama/trouser) made of cotton, (TOP-67% Cotton, 29% Polyester, 4% Spandex Woven Shirt; Bottom -67% Cotton, 29% polyester, 4% Spandex woven pant) in 2 sets/pack. The set is designed for comfort and general use and is typically categorized under apparel and clothing accessories.

3. Applicant’s interpretation of law:

The Applicant is of the opinion that the above said product falls under Chapter 62 of the HSN Classification, specifically under HSN Code 6207 or 6211, which pertains to men’s nightwear and similar apparel. However, in some cases, such garments are classified under HSN 6107 or 6108 when made of knitted fabric. The GST rate applicable as per Notification No. 01/2017-Central Tax (Rate) dated 28th June 2017 may be 5% (if the sale value per piece does not exceed Rs.1000) or 12% (if the sale value per piece exceeds Rs. 1000).

The applicant has sought advance ruling on the following questions:

Under which HSN Code should men’s pyjama sets with above mentioned description be classified?

What is the applicable GST rate on such men’s pyjama sets which are packed in 2 sets as per their buyer’s instruction and the cost of such packed pyjama sets are more than Rs. 1000.

4. The applicant is under the administrative control of Centre. The concerned authorities of the Centre and State were addressed to report if there are any pending proceedings against the applicant on the issues raised by the applicant in the ARA application and for comments on the issues raised. Remarks have been received from both the State Authority and Central Authority that there are no pending proceedings on the questions raised in their application.

5. Personal Hearing

The applicant was given an opportunity to be heard in person on 11.08.2025 vide this office memorandum No. 03/2025, dated 29.07.2025. Shri. G. Shanmugam, Advocate appeared for the personal hearing as the authorized representative (AR) of M/s. Link Up Textiles (P) Limited. The AR reiterated the submissions made in their application for advance ruling.

5.1 They explained that they are exporting Men’s Pyjamas (Shirt and Pant) two nos. each in one single pack as per the requirements of their buyer in US. They stated that they are classifying the same under HSN 6107 and clearing on payment of IGST at 12%. However, they require clarification as to whether the IGST of 5% is applicable as value of one Pyjama set is less than Rs. 1000/-.

5.2 Member requested the AR to produce copies of Purchase Order and Contract from their buyer. Member asked for details as to how the packing is accounted —– as 4-piece or 1-piece? Pricing of the product on domestic sale, if any, may be given. They were asked to provide details of any other buyer/client. The AR assured to submit the above said details /documents shortly.

5.3 The applicant vide their letter dated 18.8.2025 have furnished the copies of Export Sales Invoice, Einvoice, EWB, Bill of Lading, Shipping Bill, Purchase Order, BRC, and Sales Voucher accounted in their books. They had also stated that as their ordered Product Designs meant for exports are subject to Patent copyright with Overseas Buyers, they are not supposed to sell the same products in domestic markets.

6. Discussions and Findings:

6.1 We have carefully examined the submissions made by the applicant in their advance ruling application and the submissions made during the personal hearing. We have also considered the issue involved, the relevant facts and the applicant’s submission / interpretation of law in respect of question on which the advance ruling is sought. The applicant has sought for Advance Ruling as to the HSN code for men’s Pyjama Sets and GST rate of tax applicable for 2 Pyjama sets packed in a single pack and costing more than Rs. 1000/- per pack.

6.2 We find that the query is liable for admission as it gets covered under Section 97 (2) (b) of CGST/TNGST Act, 2017 under “applicability of a notification issued under the provisions of this Act”.

6.3 We note that the applicant is engaged in the business of exporting Men’s nightwear Pyjama set consisting of a top (kurta/shirt) made of cotton (i.e. Top-67% Cotton; 29% Polyester: 4% Spandex Woven Shirt) and bottom (pyjama/trousers) made of cotton (i.e. Bottom-67% Cotton; 29% Polyester: 4% Spandex Woven Pant). The Pyjama sets are packed in 2 nos. in a single pack as per the instructions of their buyer. The price of 1 pack of Pyjama Sets (2 tops and 2 bottoms) is Rs.1,371/ -.

6.4 We observe from the Purchase Order copy of their customer, that Order has been placed for “Men’s HANES Red Label 2 PC Sleep Set-Woven LS Top & Pant” with instructions to pack “2 Set per Bailer Bag; 12 Bailers Bag per case”. The applicant has furnished a Commercial invoice for supply of

“6516 packs of Men’s Pyjama Set: TOP-67% Cotton, 29% Polyester 4% Spandex Woven Shirt & Bottom – 67% Cotton, 29% Polyester 4% Spandex Woven Pant (2 Sets / Pack) under HSN Code 620721.90 and GST-12%”

They have also submitted a copy of Tax Invoice (e-Invoice) for supply of “6516 Nos. of Men’s Pyjama Set” under HSN 61072100 with rate of Rs. 1371/- per No. and charged to IGST at 12%. As such, it is noted that the applicant has quoted the HSN code as 620721910 & 61072100 and valued the Pyjama Set at Rs. 1,371/- and paid IGST at 12%.

6.5 We find that the product of the applicant, Men’s nightwear or Pyjama Sets consisting of a woven Top (Kurta/Shirt) and woven Bottom (Pyjama/Shirt) are made of 67% cotton, 29% Polyester and 4% Spandex. By virtue of this, the Pyjama Sets are basically made of cotton and would rightly be classifiable under HSN 620721 which reads as follows:

“HSN 620721 –

Mens or boys singlets and other vests, underpants, briefs, nightshirts, pyjamas, bathrobes, dressing gowns and similar articles – night shirts and pyjamas : of cotton”

6.6 We find that as per the Notification No. 01/2017-Central Tax (Rate) dated 28.06.2017 the rate of GST on Men’s Pyjama sets falling under Chapter 62 is as follows:

Schedule I —- @ 2.5% CGST

S.No.	Chapter/ Heading/ Sub-Heading/Tariff Item	Description of Goods
223.	62	Articles of Apparels and clothing accessories, not knitted or crocheted, of sale value not exceeding Rs. 1000/-per piece

Schedule II – – @ 6% CGST

S.no.	Chapter/ Heading/ SubHeading/Tariff Item	Description of Goods
170.	62	Articles of Apparels and clothing accessories, not knitted or crocheted, of sale value exceeding Rs. 1,000/- per piece

6.7 As per schedule-I & II above, the determination of rate of tax is based on the ‘cost per piece’. In the instant case, ‘piece’ therefore, is a single, independently usable apparel or clothing. The name of the product here is ‘pyjama’, as stated by the applicant. As per the dictionary, a pyjama’ is “a soft, loose clothing that is worn in bed and consists of trousers and a type of shirt. But in the normal parlance, it is termed as “kurta-pyjama which is a traditional South Asian garment set consisting of a kurta (a loosefitting, long, collarless shirt) and pyjama (loose trousers tied at the waist)”. In general, it is termed as ‘pyjama set’ which consists of a top and a bottom. Though, some of the retailers in India sell both kurta & pyjama as stand-alone independent piece, the product supplied by the applicant is for export and consists of ‘kurta-pyjama’ as pyjama set. Therefore, the combination of top and bottom or a ‘pyjama set’ shall be treated as a ‘piece’ and should be classified accordingly.

6.8 The applicant during the personal hearing has produced the sample product which they are exporting. As discussed in the preceding para, we are of the view that One Pyjama Set appears to consist of 1 Shirt (top) and 1 Pant (bottom) together. The applicant stated that they do not have any domestic sales of this product and they are manufacturing to order for one customer from abroad. Further the applicant stated that the Pyjama Set consisting of 1 Shirt and 1 Pant shall not be sold separately. Hence, one Pyjama Set consisting of 1 Shirt and 1 Pant has to be considered together as ‘one piece’.

6.9 The applicant is packing 2 sets of pyjamas in 1 a single pack as per the requirements of their customer abroad i.e, 2 Shirts and 2 Pants in one pack. The price of one Pack consisting of two pyjama sets is Rs. 1,371/ -. Hence, the price of one pyjama set or a piece of apparel consisting of 1 Shirt and 1 Pant is only Rs.686/- which is less than Rs. 1,000/ -. Hence, this is qualified to be classified under Schedule-I chargeable to GST at the rate of 5% (CGST-2.5% + SGST-2.5%) only under Sl. No. 223 of Notification No. 01/2017-Central Tax (Rate) dated 28.06.2017.

7. In view of the above, we rule as under:

RULING

Men’s Pyjama Sets consisting of woven Shirt and woven Pant made of cotton is to be classified under HSN code 620721.

GST rate of tax applicable for 2 Pyjama sets packed in a single pack and costing less than Rs. 1,000 per piece or set will be 5% (i.e. CGST-2.5% + SGST-2.5%) as per S.no. 223 of Schedule I of notification no. 1/2017-Central Tax (Rate) dated 28.06.2017.