Mango pulp classification under GST: taxable at 12%, not 18%, following the later departmental clarification.

Mango pulp is treated as a taxable mango product under the GST rate notifications, but it does not attract the 18% rate applied by the advance rulings. The later departmental clarification stated that mangoes under heading 0804 include mango pulp, and that mango pulp and other non-fresh forms of mango are taxable at 12%, while fresh mangoes remain exempt and sliced dried mangoes attract 5%. On that basis, mango pulp is not exempt, but its applicable GST rate is 12% rather than 18%.

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Issues: Whether mango pulp is classifiable so as to attract GST at 18% or 12%.

Analysis: The dispute turned on the correct classification of mango pulp under the GST rate notifications. An advance ruling and the appellate advance ruling had treated mango pulp/puree as falling under Tariff Item 0804 50 40 and as chargeable to GST at 18% under Entry No. 453 of Schedule III of Notification No. 1/2017-Central Tax (Rate). A later clarification issued by the Department of Revenue stated that mangoes falling under heading 0804 include mango pulp, and that all other forms of mango, including mango pulp, attract GST at 12%, while fresh mangoes remain exempt and sliced dried mangoes attract 5%.

Conclusion: Mango pulp is not exempt, but it attracts GST at 12% and not 18%.

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