Pre-packaged and labelled shrimp exports remain taxable under GST when inner packs bear printed particulars and fixed quantities.

Processed frozen shrimps exported in individual printed pouches or boxes were treated as pre-packaged and labelled goods because the relevant taxable unit was the inner pack bearing printed particulars and a predetermined quantity. The presence of an outer master carton did not change the character of the supply. The ruling held that the GST amendment covering pre-packaged and labelled commodities applied to such exports, and that the Legal Metrology framework did not create an exclusion merely because the goods were exported. Packages of 25 kilograms or less containing the specified goods therefore remained within the GST net.

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Issues: Whether export of processed frozen shrimps packed in individual printed pouches or boxes and then placed in printed master cartons of up to 25 kilograms is subject to GST as a pre-packaged and labelled commodity.

Analysis: The decisive question was whether the inner packs of processed frozen shrimp, each bearing printed particulars and having a pre-determined quantity, satisfied the statutory meaning of "pre-packaged commodity" and whether they were required to bear declarations under the Legal Metrology Act, 2009 and the rules made thereunder. The ruling treated the inner printed pouches or boxes as the relevant taxable unit, holding that the presence of an outer master carton did not alter the character of the goods. It further held that the GST amendment applying to "pre-packaged and labelled" goods covered such supplies, and that neither the notification nor the legal metrology framework created an exclusion merely because the goods were exported. The authority relied on the statutory scheme and the CBIC clarification to conclude that packages of 25 kilograms or less containing such specified goods remained within the GST net.

Conclusion: The export of processed frozen shrimps packed in individual printed pouches or boxes and placed in master cartons is liable to GST and the issue is answered against the assessee.

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