Classification of goods— In the instant case, the applicant is a public limited Company and are engaged in the business of supplying of mango pulp/puree to the dealers situated in India, including merchant export.

Questions raised before the authority:

i. Can the Mango Pulp/puree be treated as fresh fruit and exemption be claimed on it? If not whether the mango pulp/puree falls under the heading 20079910 or 0804 or 2008?

ii. What is the rate of tax payable on outward supplies of Mango fruit pulp/puree under the GST Act?

The applicant approached this authority for clarification on the classification issue of the Mango Pulp/puree, whether it can be treated as fresh fruit and exemption can be claimed on it.

In the instant case, the mangoes procured by the applicant are not marketed either in the same state or in frozen/chilled state of the same as fresh fruit. Hence, the entry under 0804 as claimed by the applicant is not applicable.

As there is no specific entry under GST tariff meant for this product 'mango pulp/puree', the entry no. 453 of Schedule -III of Notification No. 1/2017-Central Tax (Rate) dt: 28.06.2017 is applicable, which is a residuary entry covering goods which are not specified in Schedules I, II, IV, V, VI of the Notification, attracting the tax rate of 18%.

Held that— 'Mango pulp/puree', falls under the entry no. 453 of Schedule-III of Notification No.1/2017-Central Tax (Rate) dt: 28.06.2017 attracting the tax rate of 18%.