GST taxability of industrial-pack seafood remained undecided after the factual basis for exemption was not established.

Where the factual material needed to verify whether processed frozen seafood in industrial pack qualified for exclusion under the Legal Metrology rules was not produced, the AAR could not determine whether the supply was exempt or taxable under GST. Repeated opportunities of hearing were not utilised, the matter was disposed of ex parte, and no substantive advance ruling on taxability was pronounced. The absence of supporting documents meant the conditions for treating the goods as non-retail industrial or institutional packing could not be established, so the GST liability question remained undecided on merits.

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Issues: Whether the authority could pronounce an advance ruling on the taxability of supply of processed frozen seafood in industrial pack for non-retail sale on the material placed before it.

Analysis: The application was disposed of ex parte after repeated opportunities of hearing were not availed. In the absence of the applicant's participation and supporting documents, the authority was unable to verify whether the supply satisfied the conditions for exclusion under the relevant Legal Metrology rules and therefore could not determine whether the supply was exempt or taxable under the GST law.

Conclusion: No ruling on the taxability question was pronounced.

Final Conclusion: The matter ended without a substantive determination on exemption or tax liability under the GST framework.

Ratio Decidendi: Where the factual basis necessary to decide whether goods fall within the exclusion for industrial or institutional packings is not established, no advance ruling on GST liability can be rendered on merits.

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