Mango pulp classification under GST falls outside the fresh mango exemption and is taxed under the residuary entry.

Mango pulp classified under tariff item 0804 50 40 does not fall within the nil-rate entry for fresh mangoes under Notification No. 02/2017-Central Tax (Rate), because that exemption applies only to fresh fruit and not to a processed product obtained by cutting, de-stoning, refining, and packing. As mango pulp is not specifically covered by any exemption or concessional GST entry, it is taxed under the residuary goods entry in Notification No. 01/2017-Central Tax (Rate). The applicable GST rate is therefore 18%.

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Issues: Whether mango pulp falling under tariff item 0804 50 40 is covered by the nil-rate entry for fresh mangoes under Notification No. 02/2017-Central Tax (Rate), or whether it falls under the residuary taxable entry under Notification No. 01/2017-Central Tax (Rate), and what rate of GST applies.

Analysis: The nil-rate entry in Notification No. 02/2017-Central Tax (Rate) applies only to fresh mangoes. Mango pulp is a processed product obtained after cutting, de-stoning, refining, and packing, and is separately identified in the Customs Tariff as tariff item 0804 50 40. The specific classification of mango pulp does not bring it within the entry for fresh mangoes. Since mango pulp is not specifically covered in the GST tariff under the exemption or concessional schedules, it falls within the residuary entry for goods not specified elsewhere in the notification.

Conclusion: Mango pulp is not exempt as fresh mangoes and is liable to GST under the residuary entry at 18%.

Final Conclusion: The ruling fixes mango pulp in the taxable residuary category rather than the nil-rate category, and the applicable GST rate is 18%.

Ratio Decidendi: A processed product specifically classified under the Customs Tariff but not covered by a specific exempt or concessional GST entry falls under the residuary taxable entry.

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