GST Exemption on Frozen Meat Packed in Plain Gunny Bags
Maharashtra AAR ruled that frozen meat packed in gunny bags without printed fixed weights is exempt from GST.
- Ruling
- NO. GST-ARA- 17/2018-19/B- 68 dated 16.07.2018
- Dated
- 16 Jul 2018
- 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
- A meat supplier asked if frozen meat in gunny bags gets GST exemption.
- The gunny bags had no printed weight or registered brand name.
- Authority ruled non-standard gunny bags are not unit containers.
- The supply of frozen meat qualifies for full GST exemption.
In short
M.U.N. Agro Industries Pvt. Ltd. supplied frozen goat and sheep meat to the Indian Army in high-density polyethylene (HDPE) gunny bags. Under Goods and Services Tax (GST) rules, unbranded meat is exempt from tax unless it is sold in a unit container holding a predetermined quantity. The company asked if supplying meat in variable-weight gunny bags counts as a unit container, which would make the goods taxable.
What has changed
How it worked before
Before Order NO.GST-ARA- 17/2018-19/B- 68 Mumbai, businesses were unsure if bulk gunny bags constituted unit containers under GST. Many suppliers worried that packing frozen meat into large sacks for transport might strip away their tax exemption under Notification No. 02/2017-Central Tax (Rate).
What has changed
The Maharashtra Authority for Advance Ruling (AAR) decided that bulk gunny bags with varying weights are not unit containers under Chapter Tariff Heading 0204. Because the packages do not mention a fixed predetermined weight or registered brand name, the meat remains exempt from GST under Notification No. 02/2017-Central Tax (Rate). This means meat suppliers using variable-weight bulk packaging do not need to charge GST on these sales.
Who this affects
Food processors, meat exporters, and wholesale agricultural suppliers who pack unbranded frozen goods in bulk bags without standardized weight labels.
An example
A meat processing company in Pune supplies bulk frozen mutton to hotel chains in large plastic sacks. Each sack contains a different total weight based on the order size, and no fixed weight is printed on the outside. Based on ruling NO.GST-ARA- 17/2018-19/B- 68 Mumbai, the sacks are not unit containers, suggesting the sales can be exempt from GST if unbranded.
What you should do
Check if your product packaging displays a fixed, predetermined weight or a registered brand name. If your packaging varies in weight per bag, you may be eligible for a similar exemption, but remember that an advance ruling applies only to the business that asked for it. You should apply for your own advance ruling or consult a tax advisor before stopping GST collection on your goods.
If you do nothing
If you assume this ruling automatically covers your business and stop paying tax, local tax officers may disagree during an audit. If they decide your packaging qualifies as a unit container, you could face demands for unpaid GST, back interest, and penalties.
The terms explained
- Unit Container
- A package designed to hold a fixed, predetermined quantity or weight of a product that is clearly marked on the outside.
- Advance Ruling
- An official decision by tax authorities on a specific question asked by a business regarding tax rates or exemptions.
- Chapter Tariff Heading
- A standard numerical code used in tax laws to classify and identify different types of goods.
The ruling in detail
Authority for Advance Ruling
M.U.N. AGRO INDUSTRIES PVT. LTD.
NO. GST-ARA- 17/2018-19/B- 68 dated 16.07.2018 · Maharashtra
Questions before the authority
- Whether our product or goods fall under chapter tariff heading 0204 and exemption given to this tariff item vide Notification No. 02/2017 - Central Tax (Rate) dated 28/06/2017 is available to us or not?
- We are supplying meat in HDPE gunny Bag. Whether it is treated as unit container or not?
Facts
The applicant operates a private abattoir processing and freezing sheep and goat meat supplied to various command stations of the Indian Army under tenders. The frozen meat carcasses are packed and supplied in HDPE gunny bags. These bags do not have any fixed or predetermined weight printed or indicated on them, nor are they marked with a registered brand name.
Ruling
| Question | What the authority ruled |
|---|---|
| Classification under CTH 0204 and eligibility for exemption under Notification No. 02/2017-Central Tax (Rate) | Answered in the affirmative Exemption is available for frozen sheep and goat meat not put up in a unit container |
| Treatment of HDPE gunny bags as a unit container | Answered in the negative Bags containing variable weights without printed/indicated quantity fail the unit container test |
The Authority held that the applicant's supply of frozen sheep and goat meat falls under Chapter Tariff Heading 0204 and is eligible for exemption under Notification No. 02/2017-Central Tax (Rate). The HDPE gunny bags used for packing do not constitute a **unit container** because they do not bear any marking of a predetermined weight or quantity.
Reasoning
Under Explanation (i) to Notification No. 01/2017-Central Tax (Rate) and Notification No. 02/2017-Central Tax (Rate), a **unit container** must be designed to hold a predetermined quantity or number that is clearly indicated on the package. The physical verification by jurisdictional officers confirmed that each HDPE gunny bag contained varying weights of carcasses without any weight or quantity mentioned on the outer package. Since the meat is neither packed in a unit container nor bears a registered brand name, it fulfills the conditions for exemption under CTH 0204 pursuant to Notification No. 02/2017-Central Tax (Rate).
Provisions relied on
- Notification No. 01/2017-Central Tax (Rate) dated 28/06/2017
- Notification No. 02/2017-Central Tax (Rate) dated 28/06/2017
- Notification No. 44/2017-Integrated Tax (Rate) dated 14/11/2017
- Chapter Tariff Heading 0204
For the practitioner
This ruling clarifies that bulk packaging such as gunny bags used for supplying frozen meat without printed standard weights or predetermined quantities does not qualify as a **unit container**. Taxpayers supplying goods in non-standard bulk packaging can claim GST exemption where the exemption entry excludes goods put up in unit containers.
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/maha-gst-ara-17-b-68_dt.16.07.18_munipl.pdf
Legibility of the scan, as read: high.
Prepared 20-10-2026.
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