Page 146 - GSTL_14th May 2020_Vol 36_Part 2

248 GST LAW TIMES [ Vol. 36
REPRESENTED BY : Shri Jatin Mehta, for the Assessee.
[Order]. - Advance Ruling No. GUJ/GAAR/R/24/2019 (in Application
No. Advance Ruling/SGST & CGST/2018/AR/15).
2. The applicant, vide Form GST ARA-01, dated 6-4-2018, mentioned
their queries as under :
Queries
At What rate GST payable on supply of MANGO PULP falling under
Heading No. 0804 50 40 of the Customs Tariff Act, 1975 and rate of GST?
2.1 The Applicant M/s. Universal Import Export, vide attached sheet
“Annexure A” to their application dated 6-4-2018, has submitted the Statement of
Facts as under :
Background of the applicant :
(1) M/s. Universal Import Export (hereinafter referred to as the
‘applicant’) is a Partnership Firm, registered under the provi-
sions of the Partnership Act, 1932 and is engaged, inter alia, in
the supply/marketing of Agriculture Produce, the then time,
falling under Schedule-I and Schedule-II of the Gujarat Value
Added Tax Act, 2006 (in short, the ‘Act’). Registered Office of
the Firm is at 15, Tirupati Complex, Gundran Road, Talala
(Gir), District: Gir Somnath-362150. The Applicant was regis-
tered under the provisions of the Gujarat Value Added Tax
Act, 2003 (in short ‘Act’) & Central Sales Tax Act, 1956 and
hence assessed to Value Added Tax and Central Sales Tax in
the State of Gujarat under Registration No. 24121100643 and
24621100643 respectively, then on introduction of the Goods
& Services Tax regime, migrated to GST regime under Regis-
tration No. 24AAEFU7782R1Z8.
Business activity and object for Advance Ruling :
(2) Apart from dealing in Cereals & Pulses, the applicant now in-
tends to undertake local trading and export of MANGO
PULP, therefore, as an abundant caution to avoid probable
tax rate dispute, proposes to seek Advance Ruling on the
exgibility of the said Mango Pulp and at GST rate applicable.
What is Mango Pulp :
(3) Mango pulp is prepared from selected varieties of Fresh
Mango Fruit. Fully matured Mangoes are harvested, quickly
transported to the fruit processing plant, inspected and
washed. Selected high quality fruits go to the controlled rip-
ening chambers; Fully Ripened Mango fruits are then
washed, blanched, pulped, deseeded, centrifuged, homoge-
nized, thermally processed and aseptically filled maintaining
sterility. The preparation process includes cutting, de-
stoning, refining and packing. In case of aseptic product, the
pulp is sterilized and packed in aseptic bags. The refined
pulp is also packed in cans, hermetically sealed and retorted.
Frozen pulp is pasteurized and deep-frozen in plate freezers.
The process ensures that the natural flavour and aroma of the
fruit is retained in the final product.
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