GST Rate for Frozen Food Products: Karnataka Advance Ruling KAR ADRG 11/2023
The Karnataka Authority for Advance Ruling confirmed that specific frozen food products supplied in bulk are taxable at 18% GST.
- Ruling
- Advance Ruling No. KAR ADRG 11/2023 dated 21.02.2023
- 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
- SATS Food Solutions asked for the GST rate on their frozen food products.
- The products are supplied in bulk to hotels and airlines.
- The Authority classified these items under HSN 2106.
- These products are subject to an 18% GST rate.
In short
The company asked the Karnataka Authority for Advance Ruling (AAR) to clarify the Goods and Services Tax (GST) rate for their frozen food products. These items, which include ready-to-cook and ready-to-eat foods, are sold in bulk to institutional buyers like airlines and hotels. Because these products require further preparation by the buyer, the company needed to know if they qualified for a different tax category.
What has changed
How it worked before
Businesses in the food manufacturing sector often faced uncertainty regarding whether bulk-supplied frozen items should be taxed as basic food ingredients or as processed food preparations.
What has changed
The Authority ruled that these products fall under tariff heading 2106, which covers food preparations. This confirms that such items attract an 18% GST rate. For businesses, this provides a clear classification for similar products that are not yet ready for immediate human consumption.
Who this affects
Food manufacturers and suppliers who sell frozen, pre-cooked, or ready-to-cook food products in bulk to institutional clients.
An example
Imagine a frozen food manufacturer supplies bulk packs of pre-cooked vegetable patties to a chain of hotels. The hotel must thaw and fry these patties before serving them to guests. Based on this ruling, the manufacturer should classify these patties under HSN 2106 and apply an 18% GST rate.
What you should do
If you sell similar products, you should review your HSN classification against this ruling. Remember that an Advance Ruling is only legally binding on the company that requested it and their specific tax officer. You cannot automatically apply this ruling to your own business without confirming your specific product classification with your tax advisor.
If you do nothing
If you apply a lower tax rate based on this ruling without verifying your specific product's classification, you risk a tax demand from your local officer. If the department disagrees with your classification, you may be liable for the unpaid tax, interest, and potential penalties. Always consult a professional to ensure your specific products match the criteria defined in this ruling.
The terms explained
- HSN
- Harmonized System of Nomenclature is a standardized system 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.
- Tariff Heading 2106
- A specific category in the tax code that covers various food preparations not classified elsewhere.
The ruling in detail
Authority for Advance Ruling
M/s. SATS Food Solutions India Private Limited
Advance Ruling No. KAR ADRG 11/2023 dated 21.02.2023 · Karnataka
Questions before the authority
- Applicable GST rate on their products.
Facts
The applicant is a manufacturer of frozen food products, including Ready-to-Eat (RTE) and Ready-to-Cook (RTC) items, supplied in bulk institutional packs to B2B customers like airlines and hotels. These products require further processing such as thawing and cooking by the recipient before they are fit for human consumption. The applicant sought a ruling on the applicable GST rate for these products.
Ruling
| Question | What the authority ruled |
|---|---|
| Applicable GST rate on products | 18% GST (9% CGST and 9% SGST) As per entry No. 23 of Schedule III of Notification No. 1/2017-Central Tax (Rate) |
The Authority ruled that the food products manufactured by the applicant are classifiable under tariff heading 2106 and are subject to GST at the rate of 18%. This rate is applicable as per entry No. 23 of Schedule III of Notification No. 1/2017-Central Tax (Rate).
Reasoning
The Authority examined the nature of the products, which are pre-cleaned, precooked, and packaged, requiring further preparation by the buyer. It determined these products fall under tariff heading 2106, specifically covering preparations for use, either directly or after processing, for human consumption. Consequently, the products attract the **18% GST rate** under entry No. 23 of Schedule III of Notification No. 1/2017-Central Tax (Rate).
Provisions relied on
- Section 97(2)(e) of the CGST Act, 2017
- Notification No. 1/2017-Central Tax (Rate) dated 28.06.2017
- Customs Tariff Act, 1975
For the practitioner
This ruling clarifies that frozen food products supplied in bulk to institutional buyers, which require further processing, are **taxable at 18%** under HSN 2106. It helps practitioners classify similar B2B food supplies that are not ready for immediate consumption. It does not address the taxability of retail-ready food products or restaurant services.
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/knaar_order_no._112023_sats_food_solutions_1.pdf
Legibility of the scan, as read: high.
Prepared 20-10-2026.
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