Prepared or preserved pineapple classification shifts to tariff item 2008, attracting GST on the processed fruit product.

Peeling, slicing, steaming, hot filling with sugar syrup, exhausting, cooling, drying, labelling and packing materially changed the character of the pineapple from fresh fruit to a prepared or preserved product. The product was therefore not classifiable as fresh pineapple under tariff item 0804, but under tariff item 2008 as prepared or preserved pineapple, with GST applicable at 6% CGST and 6% SGST.

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Issues: Whether peeled, sliced and canned pineapple packed in sugar syrup is classifiable as fresh pineapple under tariff item 0804 or as a prepared or preserved fruit product under tariff item 2008, and the applicable GST rate.

Analysis: The product undergoes peeling, cutting, washing, steaming, hot filling with sugar syrup, exhausting, cooling, drying, labelling and packing. The process changes the character of the fruit from fresh pineapple to a prepared or preserved product. Tariff item 0804 covers fresh pineapples, whereas tariff item 2008 covers fruit and other edible parts of plants otherwise prepared or preserved, including pineapples so preserved. The applicable rate notifications place goods under tariff item 2008 in the prescribed GST slab.

Conclusion: The product is not fresh pineapple under tariff item 0804. It is classifiable under tariff item 2008 as prepared or preserved pineapple and is liable to GST at 6% CGST and 6% SGST.

Final Conclusion: The advance ruling answered the classification question against the applicant and confirmed the higher tax treatment applicable to the preserved pineapple product.

Ratio Decidendi: A fruit product that is materially processed and preserved with sugar syrup is classifiable according to its preserved character under the tariff entry for prepared or preserved fruits, not as fresh fruit.

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