There are no processes carried out on naturally available water by the Appellant and such water is also not used specifically for certain specialized purposes. The water can be used by the Appellant or it can also be sold to any other industry which uses water as an Industrial input. Thus, ideally such water should not be covered under the exclusion clause of Sr. No. 99, and may be said to be exempt. 5.11 Further, reference has been made to the ruling ofthe Tamil Nadu Appellate Authority for Advance Ruling ('AAAR'), in the case of Mis. New Tirupur Area Development Corporation Limited (ORDER-in-Appeal No. AAAR/I7&18/2021 (AR)), which deals with the question whether raw water when treated to various processes to make it potable, would become 'purified water' or it would remain to be 'treated water'. The authority stated that the meaning of'purified water' depends on what use it is to people, i.e., whether it is for washing, pharma use, industrial use or even to swim. In chemical terms, purified water is pure HO and only contains Hydrogen and Oxygen and no minerals. Distilled water is the most common form of pure water. In this context, the authority held that potable water is never to be equated to purified water. Therefore, supply ofraw water, treated to become 'potable water' is water only, and not purified water. Accordingly, such potable water would fall under the Sr. No. 99 of the Notification No.02/2017-Central Tax (Rate) for exemption.
