The Gujarat Authority for Advance Ruling (AAR) has clarified that the supply of peeled, chopped, and packed garlic will be classified under HSN code 07032000, thereby attracting no Goods and Services Tax (GST).

The ruling came in response to an application filed by a garlic processing company engaged in buying raw garlic bulbs and subjecting them to quality inspection, moisture removal, crushing, peeling, sorting, chopping, and packing before sale. The company had sought clarity on three points — whether such activity amounted to “manufacture,” how the product should be classified under GST tariff codes, and whether GST was payable.

On the first question, the AAR declined to rule on whether the process amounted to “manufacture.” It noted that this issue was not among the seven specific matters listed in Section 97(2) of the CGST Act, 2017, on which an advance ruling can be sought.

The applicant argued that the processed garlic should fall under HSN 20055900 (“other vegetables prepared or preserved otherwise than by vinegar or acetic acid, not frozen”), attracting 12% GST, since it was no longer fresh after undergoing processing.

However, the AAR held that peeled and chopped garlic remains covered under Chapter 7 (“Onions, shallots, garlic, leeks and other alliaceous vegetables, fresh or chilled”). The authority relied on the explanatory notes of Chapter 7, which explicitly include vegetables that are whole, sliced, chopped, shredded, pulped, grated, peeled, or shelled. Since the garlic remained in a fresh or chilled state despite processing, it continued to fall under HSN 07032000.

As per Notification No. 2/2017-Central Tax (Rate) dated June 28, 2017, goods under HSN 0703 attract nil GST. Therefore, the AAR ruled that the applicant was not required to pay GST on the supply of peeled and chopped garlic.

The final ruling stated that the manufacturing question was not answered, the product classification would be under HSN 07032000, and no GST liability would arise.

Ruling Details

Applicant’s Name: Purnam Cuisines Pvt ltd.

Ruling Date: 26/06/2025

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