Specific tariff entry prevails for mango pulp/puree; absent concessional coverage, GST applies at the residuary rate.

Mango pulp/puree is classified under Tariff Item 0804 50 40 as mango pulp, because a specific tariff description prevails over a general or residuary classification and Chapter 20 does not override the Chapter 8 entry. The attempt to classify the product under Chapter 2007 or a residuary entry was rejected. On GST rate, the note states that fresh mangoes alone are exempt and no specific concessional entry covers mango pulp/puree, so it falls under the residuary Schedule III entry for goods not specified elsewhere and is taxable at 18%. The limited classification point was accepted, but no substantive tax relief followed.

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Issues: (i) Whether mango pulp/puree is classifiable under Chapter Heading 0804 as mango pulp or under Chapter Heading 2007 or any residuary entry. (ii) What rate of GST is applicable to mango pulp/puree under the relevant notification.

Issue (i): Whether mango pulp/puree is classifiable under Chapter Heading 0804 as mango pulp or under Chapter Heading 2007 or any residuary entry.

Analysis: The rate notification is to be interpreted with the Customs Tariff, including section notes, chapter notes, and the general interpretative rules. A specific tariff description prevails over a general one. The product finds a specific entry as mango pulp under Tariff Item 0804 50 40 in Chapter 8. Chapter 20 does not cover fruits or nuts prepared or preserved by the processes specified in Chapter 8. The attempt to place the product under Chapter 2007 was therefore rejected, and the technical description of pulp and puree did not alter the tariff position.

Conclusion: Mango pulp/puree is classifiable under Tariff Item 0804 50 40 and not under Chapter Heading 2007 or the residuary entry on the basis urged by the appellant.

Issue (ii): What rate of GST is applicable to mango pulp/puree under the relevant notification.

Analysis: Fresh mangoes alone are covered by the exempt entry, and the later amendment concerning sliced dried mangoes did not create any specific concessional entry for mango pulp. Since mango pulp/puree is not specifically covered in the concessional schedules, it falls within the residuary Schedule III entry for goods not specified elsewhere, attracting tax at 18%.

Conclusion: Mango pulp/puree is chargeable to GST at 18% under the residuary entry in Schedule III.

Final Conclusion: The appeal succeeded only to the limited extent of the tariff classification, but the applicable tax rate remained 18%, so the appellant obtained no relief on the substantive tax liability.

Ratio Decidendi: Where a goods description has a specific tariff entry, that entry prevails over general or residuary classifications, and in the absence of a specific concessional entry the goods are taxable under the residuary schedule.

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