In re Sprint Exports Pvt Ltd (GST AAR Andhra Pradesh)
M/s. Sprint Exports Pvt Ltd (the Applicant), a registered entity in Andhra Pradesh, filed an application for an Advance Ruling to clarify the Goods and Services Tax (GST) liability on the export of pre-packaged and labelled processed shrimp. The clarification was sought in light of changes to tax rates introduced by Notification No. 06/2022-CGST (R) dated July 13, 2022.
Applicant’s Business and Packaging
The Applicant is engaged in the business of processing and exporting shrimp. The processing involves washing, de-veining, peeling, de-heading, tail removal, sorting, grading, and freezing, using either Individual Quick Freezing (IQF) or Block Freezing techniques. The processed frozen shrimp (HSN: 0306) are packaged according to buyer specifications for export:
- Primary Packaging (Inner Packing): Individual pouches or boxes, typically weighing between 250 grams and 2 kilograms. This packaging is the principal container and is printed with product details, weight, branding, and other specifications (i.e., packaged and labelled).
- Secondary Packaging (Outer Packing): The primary packages are placed into master cartons with a maximum weight limit of 25 kilograms. Both primary and secondary packaging are printed.
Questions Raised Before the Authority
The Applicant sought an advance ruling on two specific questions, both concerning the export of processed frozen shrimps (HSN: 0306) in packages up to 25 kgs:
