GST rate on mango pulp treated as 12% after circular was read as clarificatory, not prospective.

A circular dated 03.08.2022 clarifying the GST rate on mango pulp was treated as an explanatory clarification, not a prospective change in law. The circular stated that dried mangoes, including mango pulp, were always intended to fall under the 12% GST entry, and the clarification was issued to remove ambiguity in the tariff classification. On that basis, mango pulp was treated as taxable at 12% for the relevant period, and the earlier Division Bench view on the classification was followed.

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Issues: Whether the circular issued on 03.08.2022, clarifying the GST rate on mango pulp, operated only prospectively or also applied to earlier tax periods, and whether mango pulp attracted GST at 12%.

Analysis: The circular stated that all forms of dried mangoes, including mango pulp, were always meant to attract GST at 12%, and the clarification was issued only to bring absolute clarity to the relevant tariff entry. In that setting, the Court held that the clarification could not be treated as a purely prospective change in law. The earlier Division Bench view on mango pulp was followed, and the rate on mango pulp was treated as 12% for the relevant period.

Conclusion: The challenge to the assessment failed on merits and the petitioner succeeded; the applicable GST rate on mango pulp was 12%, not 18%.

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