GST on pre-packaged labelled rice applies even when supplies are meant for export or bill-to-ship-to movement.

GST applies to supplies of pre-packaged and labelled rice up to 25 kg because the amended rate entry covers commodities required to bear declarations under the Legal Metrology framework. The ruling relied on the linked Legal Metrology definition and the Ministry of Finance clarification to confirm that such rice falls within the taxable description when supplied in pre-packaged and labelled form within the prescribed quantity. The fact that the goods were intended for export did not change the tax treatment. GST is therefore leviable on direct export supplies, bill-to-ship-to supplies, and supplies to an exporter's factory for subsequent export.

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Issues: Whether GST is leviable on supply of pre-packaged and labelled rice up to 25 kg, including supplies made directly to a foreign buyer, to an exporter on bill-to-ship-to basis, and to the exporter's factory for ultimate export.

Analysis: The ruling turned on the scope of the amended GST entry for pre-packaged and labelled commodities and the linked definition under the Legal Metrology Act, 2009. The relevant notification substituted the expression in the rate schedule and made taxable supplies of commodities that are required to bear declarations under the Legal Metrology framework. The clarification issued by the Ministry of Finance was also relied upon to note that specified food items such as rice, when supplied in pre-packaged and labelled form within the prescribed quantity, fall within the taxable description. The fact that the goods were ultimately intended for export did not alter the character of the supply for GST purposes.

Conclusion: GST is leviable on all the three categories of supply of pre-packaged and labelled rice up to 25 kg, whether made directly for export, on bill-to-ship-to basis, or to the exporter's factory for subsequent export.

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