Specific tariff entry for mango pulp prevails over general headings, with GST applied under the residuary rate entry.

Mango pulp/puree is treated as Tariff Item 0804 50 40 because a specific tariff entry for mango pulp prevails over broader references to fresh fruit, Heading 2007, or Heading 2202. Chapter 20 was found inapplicable since fruit prepared or preserved by the processes covered in Chapter 8 is excluded from that chapter. As no specific GST rate entry covered mango pulp/puree in the relevant schedule, the residuary entry in Schedule III applied, making the product liable to GST at 18%.

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Issues: Whether mango pulp/puree is classifiable as fresh fruit or under Heading 2007 or Heading 2202, and what rate of GST applies to it.

Analysis: The applicable rate notification must be interpreted with reference to the First Schedule to the Customs Tariff Act and the Section Notes and Chapter Notes. The product was found to fall under Tariff Item 0804 50 40 as mango pulp, and Chapter 20 was held inapplicable because fruit prepared or preserved by the processes specified in Chapter 8 is excluded from Chapter 20. The claim for classification under Heading 2007 or as a drink under Heading 2202 was rejected because a specific tariff entry for mango pulp prevails over general descriptions. Since no specific GST rate entry covered mango pulp/puree in the relevant schedule, the residuary entry in Schedule III was applied.

Conclusion: Mango pulp/puree is classifiable under Tariff Item 0804 50 40 and is liable to GST at 18% under the residuary entry.

Final Conclusion: The appellate ruling was modified on classification, but the product remained taxable at 18% under the GST rate notification.

Ratio Decidendi: Where a specific tariff entry exists for a product, it prevails over competing general headings, and goods not covered by any specific schedule entry fall within the residuary rate entry.

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