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Advance rulings (AAR) Goa

GST Rate and Classification for Cashew Apple Juice (Nira/Niro)

The Goa Authority for Advance Ruling confirmed that cashew apple juice is taxable at 5% GST under HSN code 2009.

Ruling
GOA/GAAR/06 of 2025-26/4376 dated 31/12/2025
Dated
31 Dec 2025
Authority
Authority for Advance Ruling

This page was written by Patron Accounting’s AI from the official release and reviewed before publishing. It explains the document in plain language. It is not the document itself. Where this page and the original differ, the original governs.

The short version

  1. Cashew apple juice (Nira/Niro) is not exempt from GST.
  2. The product is classified under HSN code 2009.
  3. The applicable GST rate is 5%.

In short

The company asked the Goa Authority for Advance Ruling (GAAR) whether their cashew apple juice product, Nira or Niro, qualifies for a GST exemption. The authority examined the product's ingredients and manufacturing process to determine its correct tax treatment. They concluded that the juice is a taxable product rather than an exempt one.

What has changed

How it worked before

Manufacturers of fruit-based beverages often face uncertainty regarding whether specific natural juices qualify for GST exemptions or fall under taxable categories.

What has changed

The authority ruled that Nira/Niro falls under HSN 2009, which covers unfermented fruit juices. This means businesses must collect and pay 5% GST on these sales. This ruling clarifies that such products do not qualify for tax-free status.

Who this affects

Manufacturers and distributors of cashew apple juice or similar fruit-based beverages.

An example

A beverage company in Maharashtra produces a similar cashew apple juice with preservatives. They might wonder if they can sell it tax-free. Based on this ruling, they should expect that their product is likely taxable at 5% and should consult their tax advisor to confirm their specific classification.

What you should do

If you produce similar juice, you should review your product classification against this ruling. Remember that an advance ruling only binds the business that requested it and their specific tax office; it is not a universal law for all businesses.

If you do nothing

If you assume this ruling applies to you and stop collecting GST, you risk a tax demand, interest, and penalties if your local officer disagrees. Tax authorities may view the failure to collect tax as a compliance error, leading to audits and potential litigation.

The terms explained

HSN code
A standardized system of numbers used to classify goods for taxation purposes.
Advance ruling
A formal decision provided by tax authorities to a business regarding the tax treatment of a specific transaction.
Exemption
A provision that allows certain goods or services to be sold without the requirement to pay GST.

The ruling in detail

Authority for Advance Ruling

DUDHSAGAR BREWERIES & DISTILLERIES

GOA/GAAR/06 of 2025-26/4376 dated 31/12/2025 · Goa

Questions before the authority

  • Whether the manufacture and sale of the product NIRA or NIRO is liable to GST.
  • If liable, the appropriate HSN classification under the GST Tariff and the applicable rate of GST.
  • If exempt, the relevant exemption notification or classification under which such exemption is available.

Facts

The applicant is a registered taxpayer engaged in the business of manufacturing alcoholic beverages and related products. They are launching a new non-alcoholic beverage called Cashew NIRA, also known as NIRO, which is a juice obtained from crushing cashew apples. The product is described on the label as clarified cashew apple juice with preservatives E221, E223, and E330.

Ruling

QuestionWhat the authority ruled
Liability to GSTLiable to GST
Not exempt
HSN Classification and RateHSN 2009 at 5 percent GST
2.5 percent CGST and 2.5 percent SGST
ExemptionNot exempt
No exemption notification applicable

The authority ruled that the product is liable to GST. It is classified under HSN 2009 and is subject to a total GST rate of 5 percent. The ruling confirms that the product does not qualify for an exemption.

Reasoning

The authority determined that the product falls under HSN 2009, which covers fruit or nut juices that are unfermented and do not contain added spirit. This classification is based on the product label and the process flowchart provided by the applicant. The applicable rate of 5 percent is derived from Schedule I, serial number 133 of the relevant GST Rate Notifications issued by the CBIC and the Government of Goa. The ruling is contingent upon the accuracy of the information provided by the applicant regarding the product contents and manufacturing process.

Provisions relied on

  • Section 97 of the CGST/SGST Act, 2017
  • Section 98 of the CGST/SGST Act, 2017
  • HSN Code 2009
  • Schedule I, serial number 133 of GST Rate Notification No. 9/2025-Central Tax (Rate)
  • Notification No. 38/1/2017-Fin(R&C)(09/2025-Rate)

For the practitioner

This ruling provides clarity for manufacturers of **cashew apple juice** regarding its taxability and classification. It confirms that such products are **taxable at 5 percent** under HSN 2009 rather than being exempt. Practitioners should note that this ruling is strictly based on the specific product composition and labeling provided by the applicant.

Source

This is a summary prepared from the published order, which is a scanned document. It is a reading aid and not the authority: where the two differ, the order governs. Verify every provision against the original before relying on it.

Original order: https://www.gstcouncil.gov.in/sites/default/files/AAR/13-order_gst_ara_dudhsagarbreweries.pdf

Legibility of the scan, as read: high.

Prepared 12-10-2026.

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Is this ruling binding on my business?

No. An advance ruling is only legally binding on the business that applied for it and the tax authorities overseeing that specific case.

Does this mean all fruit juices are taxed at 5%?

Not necessarily. Tax rates depend on the specific HSN classification of the product, which is determined by its ingredients and manufacturing process.

What if my local tax officer disagrees with this ruling?

Since this ruling is not a general law, your local tax officer is not required to follow it. You should seek professional advice to determine the correct tax treatment for your specific product.

How do I apply for my own ruling?

You can file an application with the Authority for Advance Ruling in your state under Section 97 of the GST Act to get clarity on your specific product.