Waters at 5%, flavoured drinks at 40%
Notification 9/2025-Central Tax (Rate) lists waters, including natural or artificial mineral waters and aerated waters, not containing added sugar or other sweetening matter nor flavoured, under 2201 in the 5% schedule, along with ice and snow under 2201 90 10. Waters containing added sugar or flavouring under 2202 10 are in the 40% schedule. A plant that adds a flavoured water or soda line must keep those products on separate invoice lines at their own rate.
Jar deposits are not sales
Refundable deposits for 20 litre jars are security deposits, not consideration for supply, as long as they are refundable. If jars are not returned and deposits are forfeited, consider whether that amounts to a sale of the jar and raise an invoice if it does.
Composition for small plants
Small water plants selling only within the state may opt for composition, but the scheme is not available to manufacturers of certain notified goods. Check the current exclusion list before opting in, because aerated waters have historically been excluded.
FSSAI and BIS details
FSSAI requires licence or registration numbers on invoices and bills. BIS certification is required for packaged drinking water. Invoices should carry both to satisfy distributors and institutional buyers.
E-way bills for distribution
Water is low-value per unit, so many delivery loads are below ₹50,000, but full truck loads to distributors may exceed it. Check each consignment.
Bottles, caps and the inverted duty question
Water plants buy PET preforms, caps, labels and shrink film, mostly at 18%, while their output water is at 5%. Plants that blow their own bottles may build up credit that cannot be used against 5% output tax. A refund under section 54(3) for inverted duty may be available on input credit, subject to the Rule 89(5) formula. Input services such as transport and repairs do not count in that formula. Keep purchase invoices organised by HSN so the claim can be supported.
Route sales and daily deliveries
Many plants supply offices and shops on daily routes, often to unregistered buyers. Where an individual supply to an unregistered buyer is below ₹200 and the buyer does not ask for an invoice, Rule 46 allows a consolidated tax invoice at the end of the day, but each delivery must still be recorded in the route sheet. When the route vehicle carries goods for several customers, the delivery challan or invoice for each drop should travel with it.