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3. As seen from the record, by an order dated 27.07.2022, this Court, taking into consideration the submissions made across the Bar, directed the respondents herein not to take any coercive steps for recovery of GST @ 18% as contemplated by them in respect of past transactions and insofar as future transactions are concerned, in view of the dispute as to whether 'mangoes' mentioned in the notification include 'mango pulp', directed that petitioner shall pay GST @ 18%.

4. The question that arises for consideration in the present writ petition is: Whether the authorities were right in charging GST, in respect of 'Mango Pulp', @ 18%?

"4. Mangoes under CTH 0804 including mango pulp, but other than fresh mangoes and sliced, dried mangoes, attract GST at 12% rate:
4.1. Representations have been received seeking clarification regarding the applicable GST rate on different forms of Mangoes including Mango Pulp.
4.2. On the basis of the recommendation of the GST Council in its 22 Meeting, the GST rate on Mangoes sliced, dried', falling under heading 0804, was reduced from 12% to 5% [S. No. 30A of Schedule I of notification No. 1/2017-Central Tax (Rate) dated the 28th June, 2017]. However, the GST rate on all forms of dried mangoes (other than sliced and dried mangoes), falling under heading 0804, including mango pulp, was always meant to be at the rate of 12%.
4.4. Fresh mangoes, falling under heading 0804, continue to remain exempt from GST (S.No. 51 of notification No. 2/2017-

Central Tax (Rate), dated the 28th June, 2017]."

7. From a reading of the above, it is very clear now that on the basis of recommendation of GST Council in its 22nd meeting, the GST rate on 'Mangoes sliced, dried' falling under heading 0804 was reduced from 12% to 5% while GST rate on all forms of dried mangoes (other than sliced and dried mangoes) falling under heading 0804, including mango pulp, was always meant to be at the rate of 12%. Therefore, the petitioner is liable to pay GST on Mango pulp @ 12%.

8. In view of the above, orders passed by the Appellate Authority for Advance Ruling imposing GST in respect of 'mango pulp' @ 18% is incorrect and it is made clear that the petitioner is liable to pay GST in respect of Mango pulp @ 12%.

9. Accordingly, the Writ Petition is disposed of. There shall be no order as to costs.

Miscellaneous petitions pending, if any, in this Writ Petition shall stand closed.

_______________________________ JUSTICE C.PRAVEEN KUMAR ________________________________ JUSTICE A.V.RAVINDRA BABU 14.09.2022 Vjl THE HONOURABLE SRI JUSTICE C.PRAVEEN KUMAR AND THE HONOURABLE SRI JUSTICE A.V.RAVINDRA BABU WRIT PETITION No.17267 of 2022 Date : 14.09.2022 Vjl