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July 13, 2022

For GST exemption, Mango Pulp cannot be treated as fresh fruit

by CA Shivam Jaiswal in GST, GST Circular Notification

Facts and Issues

 M/s. Sri Manjunatha Fruit Canning Industries is a partnership firm registered under the partnership Act, 1932, and engaged in the business of supplying of mango pulp/puree to the dealers situated in India, including merchant export. The applicant submitted the manufacturing process of the Mango pulp/puree as under.

The applicant states that selected varieties of fresh mango fruits are procured and transported to the fruit processing plant. The fruits are inspected, graded and washed and sent to the controlled ripening chambers. The fully ripened mango fruits are then washed, blanched, pulped, deseeded, centrifuged, homogenized, and thermally processed. The preparation process includes cutting, de-stoning, refining and packing. The refined pulp is packed in cans, hermetically sealed and retorted. The applicant claims, this process ensures the retention of the natural flavor and aroma of the fruit in the final product. Main varieties of Mango Pulp are Alphonso Mango Pulp, Totapuri Mango Pulp, Kesar Mango Pulp etc. Such extracted Mango Pulp/puree is sold in India, including Merchant Exporters.

 The applicant submits that the product in question is called ‘pulp’ in some countries and ‘puree’ in some other countries. Mango Pulp is perfectly suited for conversion into juices, nectars, drinks, jams, fruit cheese and various other kinds of beverages besides its direct consumption in lieu of fresh fruit. It can also be used in puddings, bakery fillings, fruit meals for children and flavors for food industry, and also to make the most delicious ice creams, yoghurt and confectionery.

Observations by the Court

The Court has examined the issues raised in the application. The taxability of the goods supplied, as governed under the provisions of respective GST Acts is examined to decide the question involved in the present filing.

The applicant approached this authority for clarification on the classification issue of the Mango Pulp/puree, whether it can be treated as fresh fruit and exemption can be claimed on it.

In the instant case, the mangoes procured by the applicant are not marketed either in the same state or in frozen/chilled state of the same as fresh fruit. Hence, the entry under 0804 as claimed by the applicant is not applicable.


Question: Can the Mango Pulp be treated as fresh fruit and exemption be claimed? If not whether the mango pulp falls under the heading 20079910 or 0804? Answer: Negative

Question: What is the rate of tax payable on outward supplies of Mango fruit pulp under the GST Act?

Answer: ‘Mango pulp/puree’, falls under the entry no. 453 of Schedule-III of Notification No.1/2017-Central Tax (Rate)  attracting the tax rate of 18%.


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