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Issues: (i) Classification (tariff items/HSN) of non-alcoholic beverages, iced tea preparations, syrups and beverage concentrates, and extracts/essences/concentrates of tea; (ii) Correctness of HSN/tariff item numbers proposed by the applicant; (iii) Whether the products fall under Schedule I or Schedule III of the rate notification; (iv) Applicable GST rates under GST 2.0 for the said products.
Issue (i): Classification (tariff items/HSN) of non-alcoholic beverages, iced tea preparations, syrups and beverage concentrates, and extracts/essences/concentrates of tea.
Analysis: Classification was determined by comparing product composition and manufacturing process with the Customs Tariff headings and subheadings. Non-alcoholic beverages lacking fruit pulp/juice match heading 2202 and the subheading 2202 99 90. Iced tea preparations and extracts/essences/concentrates of tea correspond to heading/subheading 2101/2101 20. Syrups and beverage concentrates correspond to heading/subheading 2106/2106 90 and specifically tariff item 21069019 based on their formulation and use as concentrates for beverage preparation.
Conclusion: Non-alcoholic beverages: tariff item 22029990. Iced tea preparations and tea extracts/essences/concentrates: subheading 210120 (heading 2101). Syrups and beverage concentrates: tariff item 21069019.
Issue (ii): Correctness of HSN/tariff item numbers proposed by the applicant.
Analysis: The applicant-proposed code 22029020 was not found in the tariff schedule; nearest relevant entries were examined. Tariff numbering and descriptions in the Customs Tariff Act, 1975 were applied to the product descriptions and manufacturing details to verify exact subheading/ tariff item.
Conclusion: The applicant's code 22029020 is incorrect; correct codes are 22029990 for non-alcoholic beverages, 210120 (subheading) for iced tea and tea extracts, and 21069019 for syrups and beverage concentrates.
Issue (iii): Whether the products fall under Schedule I or Schedule III of the rate notification.
Analysis: Relevant entries of Notification No. 1/2017 - Central Tax (Rate) (as amended by Notification No. 09/2025) were mapped to the identified tariff items. The Schedule I and Schedule III entries and their serial numbers were applied to the classified tariff items to determine placement.
Conclusion: Non-alcoholic beverages (tariff item 22029990) qualify under Schedule III (serial no. 2). Iced tea preparations and extracts/essences/concentrates of tea (subheading 210120) fall under Schedule I (serial no. 136). Syrups and beverage concentrates (21069019) fall under Schedule I (serial no. 145).
Issue (iv): Applicable GST rates under GST 2.0 for the said products.
Analysis: The applicable GST rates were determined by reference to the Schedule entries in Notification No. 1/2017 - Central Tax (Rate) as amended by Notification No. 09/2025 and the tariff items assigned to the products.
Conclusion: Non-alcoholic beverages (22029990) are taxable at 20% CGST + 20% SGST. Iced tea preparations and extracts/essences/concentrates of tea (210120) are taxable at 2.5% CGST + 2.5% SGST. Syrups and beverage concentrates (21069019) are taxable at 2.5% CGST + 2.5% SGST.
Final Conclusion: The advance ruling specifies tariff items and corrects the applicant's proposed HSN numbers, designates the respective Schedule entries under the amended rate notification, and fixes the GST rates for each product category, with some of the applicant's requests accepted and others revised by the Authority.
Ratio Decidendi: Classification and applicable GST rates are determined by matching product composition and manufacturing process to the precise Customs Tariff Act headings/subheadings and then applying the corresponding entries in Notification No. 1/2017 - Central Tax (Rate) as amended by Notification No. 09/2025.