Sage Organics’ non-alcoholic beverages fall under HSN 2202, while iced tea and syrups fall under Chapter 21.
Issue
Whether the low-calorie, sugar-free non-alcoholic beverages, iced tea preparations, and flavoured syrups manufactured by the applicant classify under Chapter 21 or Chapter 22 of the HSN, which Schedule of the GST rate notifications they qualify for, and what the applicable GST rates are under GST 2.0.
Facts
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The Applicant: Sage Organics Private Limited manufactures and supplies healthy, low-calorie, sugar-free non-alcoholic beverage preparations.
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Product Portfolio: The products include Iced Tea preparations, flavoured syrups, and Instant Tea mixes marketed as beverage bases to be reconstituted or diluted before consumption.
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The Request: The applicant sought an advance ruling from the West Bengal Authority for Advance Ruling to determine the correct HSN codes, applicable Schedules, and tax rates.
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Ingredients: The non-alcoholic beverages in question do not contain any fruit pulp or fruit juice.
Decision
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Non-Alcoholic Beverages (Without Fruit Juice/Pulp): Classified under HSN 2202 99 90 (as they do not qualify as fruit juice-based drinks under 2202 99 20). They fall under Schedule III (Serial No. 2) of Notification No. 1/2017-Central Tax (Rate), as amended by Notification No. 09/2025. Tax Rate: 40% total (20% CGST + 20% SGST). (In favour of Revenue)
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Iced Tea Preparations & Tea Extracts/Essences: Classified under HSN 2101 20. They fall under Schedule I (Serial No. 136) of the amended notification. Tax Rate: 5% total (2.5% CGST + 2.5% SGST). (In favour of Assessee)
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Syrups and Beverage Concentrates: Classified under HSN 2106 90 19. They fall under Schedule I (Serial No. 145) of the amended notification. Tax Rate: 5% total (2.5% CGST + 2.5% SGST). (In favour of Assessee)
Key Takeaways
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Absence of Fruit Content Shifts Classification: Non-alcoholic beverages without fruit pulp or juice cannot claim lower-rate classifications designated for fruit drinks and are pushed into the residual “other” category under HSN 2202 99 90, attracting a significantly higher tax rate (40%).
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Chapter 21 vs. Chapter 22 Differentiation: Beverage bases like tea extracts (2101) and syrups/concentrates (2106) enjoy a much lower GST rate (5%) compared to ready or near-ready non-alcoholic water-based beverage preparations falling under Chapter 22.
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Impact of GST 2.0 Amendments: The ruling highlights how recent amendments (Notification No. 09/2025) strictly map product ingredients to specific entry items, heavily penalising synthetic or non-fruit-based liquid refreshments.
AUTHORITY FOR ADVANCE RULING , WEST BENGAL
Sage Organics (P.) Ltd., In re*
JAYDIP KUMAR CHAKRABARTI and SHAFEEQ S., Member
Order No. 36/WBAAR/2025-26
FEBRUARY 27, 2026
1.1 At the outset, we would like to make it clear that the provisions of the Central Goods and Services Tax Act, 2017 (the CGST Act, for short) and the West Bengal Goods and Services Tax Act, 2017 (the WBGST Act, for short) have the same provisions in like matter except for certain provisions. Therefore, unless a mention is specifically made to such dissimilar provisions, a reference to the CGST Act would also mean reference to the corresponding similar provisions in the WBGST Act. Further to the earlier, henceforth for the purposes of these proceedings, the expression “GST Act” would mean the CGST Act and the WBGST Act both.
1.2 The applicant, Sage Organics Private Limited, is engaged in the manufacture and supply of healthy, low calorie and sugar free non-alcoholic beverage preparations intended for human consumption. The product portfolio of the applicant includes items such as Iced Tea preparations, flavoured syrups and Instant Tea mixes, which are manufactured and marketed as beverage bases to be reconstituted or diluted before consumption.
1.3 The applicant has made this application under sub-section (1) of section 97 of the GST Act and the rules made there under seeking an advance ruling in respect of following questions:
| • | Non-alcoholic beverage/Iced Tea preparation (HSN 22029020) |
| • | Syrups and beverage concentrate (HSN 21069019) |
| • | Extracts, essences and concentrates of tea (HSN 21012010) |
Please clarify if the above mentioned HSN Code is correct? If found incorrect, kindly provide the correct HSN Code.
| (b) | What is the appropriate classification under GST 2.0 for the following products: |
| • | Non-alcoholic beverage/Iced Tea preparation |
| • | Syrups and beverage concentrate |
| • | Extracts, essences and concentrates of tea |
| (c) | Whether these products qualify under Schedule II or III of the new GST rate notifications for food/beverage items? |
| (d) | What is applicable GST rate under GST 2.0? |
1.4 The aforesaid questions on which the advance ruling is sought for are found to be covered under clause (a) of sub-section (2) of section 97 of the GST Act.
1.5 The applicant states that the questions raised in the application have neither been decided by nor are pending before any authority under any provision of the GST Act.
1.6 The officer concerned from the Revenue has raised no objection to the admission of the application.
1.7 The application is, therefore, admitted.
2. Submission of the Applicant
2.1 The Applicant respectfully submits that it is engaged in the manufacture and supply of healthy, low calorie and sugar free non alcoholic beverage preparations including iced tea preparations, syrups and beverage concentrates, and extracts, essences and concentrates of tea intended for human consumption. The present application has been filed seeking clarification regarding the appropriate classification of the said products under GST 2.0, applicability of Schedule II or Schedule III of the relevant rate notifications, and the applicable rate of tax.
2.2 The Applicant submits that iced tea preparations are non-alcoholic beverage preparations falling under Chapter 22 of the Customs Tariff. These products are either ready to serve or ready to mix beverage bases meant for dilution before consumption. They are neither alcoholic beverages nor aerated drinks and are manufactured as processed beverage items intended for general human consumption.
2.3 The Applicant further submits that syrups and beverage concentrates are edible preparations falling under Chapter 21 of the Customs Tariff. These products are prepared formulations intended to be mixed with water, soda or other liquids for preparation of beverages. They are processed food preparations and are not in the nature of luxury or demerit goods.
2.4 The Applicant also submits that extracts, essences and concentrates of tea are processed derivatives of tea intended for preparation of beverages and fall under Chapter 21. These products are manufactured using tea extracts and are supplied as beverage ingredients for human consumption.
2.5 The Applicant submits that the products in question are processed food and beverage items and do not fall under the category of luxury goods or sin goods such as alcoholic beverages, tobacco products or aerated drinks. The products are sugar free, health oriented beverage preparations and are marketed as alternatives to high sugar drinks. Accordingly, they are eligible to be considered under Schedule II of the GST rate notifications and not under Schedule III.
2.6 The Applicant submits that under GST 2.0, tax rates have been rationalized into slabs such as 5 percent, 12 pe rcent, 18 per cent and higher rates for specified goods. Based on the nature and character of the products:
| • | Non alcoholic iced tea preparations attract GST at 12 per cent. |
| • | Syrups and beverage concentrates attract GST at 18 per cent. |
| • | Extracts, essences and concentrates of tea attract GST at 18 per cent. |
2.7 The Applicant submits that the above rate structure is consistent with the legislative intent to tax processed food and beverage preparations at moderate rates while reserving higher tax rates for luxury or demerit goods. The products supplied by the Applicant are standard consumer beverage preparations and therefore merit taxation at the rates stated above.
2.8 In view of the above submissions, the Applicant prays that this Hon’ble Authority may confirm the appropriate classification of the products, hold that they fall under Schedule II of the GST rate notifications, and declare that the applicable GST rates are 12 per cent for iced tea preparations and 18 percent for syrups, beverage concentrates and tea extracts.
3. Submission of the Revenue
3.1 The Revenue has furnished its opinion in respect of the application for Advance Ruling filed by Sage Organics Private Limited. The opinion is stated to be based on State Tax (Rate) Notification No. 1630-F.T., dated 19.09.2025 and the corresponding Central Notification No. 09/2025-Central Tax (Rate).
3.2 In respect of the question regarding correctness of HSN classification, the Revenue has stated that no specific HSN code was found mentioned in the application and, therefore, no opinion could be offered on the correctness of the same.
3.3 Regarding classification under GST 2.0, the Revenue has opined as follows:
| (i) | Non-alcoholic beverages fall under Schedule III and are taxable at 20 per cent SGST and 20 per cent CGST or 40 per cent IGST under SL. No. 2 of the notification, covering tariff items 2202 91 00 and 2202 99 90 described as “Other non-alcoholic beverages [other than those specified in Schedule I]”. |
| (ii) | Iced tea preparation falls under Schedule I and is taxable at 2.5 per cent SGST and 2.5 percent CGST or 5 per cent IGST under Sl. No. 136, tariff item 2101 20, described as “Extracts, essences and concentrates of tea or mate, and preparations with a basis of these extracts, essences or concentrates or with a basis of tea or mate”. |
| (iii) | Syrups and beverage concentrates fall under Schedule III and are taxable at 20 per cent SGST and 20 per cent CGST or 40 per cent IGST under Sl. No. 1 covering tariff items 2202 91 00 and 2202 99 90 described as “All goods (including aerated waters), containing added sugar or other sweetening matter or flavoured”. |
| (iv) | Extracts, essences and concentrates of tea fall under Schedule I and are taxable at 2.5 per cent SGST and 2.5 per cent CGST or 5 per cent IGST under S. No. 136, tariff item 2101 20. |
3.4 In response to the query whether the products qualify under Schedule II or Schedule III of the revised GST rate notifications, the Revenue has reiterated its opinion as stated above, classifying non-alcoholic beverages and syrups under Schedule III and tea extracts and iced tea preparations under Schedule I.
3.5 With regard to the applicable GST rate under GST 2.0, the Revenue has reiterated that the rates shall be as indicated above, namely 40 per cent (20 percent SGST + 20 per cent CGST) for non-alcoholic beverages and syrups falling under Schedule III, and 5 percent (2.5 per cent SGST + 2.5 percent CGST) for iced tea preparations and tea extracts falling under Schedule I.
4. Observations & Findings of the Authority
4.1 We have gone through the records of the issue as well as submissions made by the authorized representative of the applicant during personal hearing. We have also considered the view given by the Revenue.
4.2 According to the facts narrated and submissions made by the applicant, it is a company engaged in the manufacturing and supplying of various non-alcoholic beverages and related preparations such as Iced tea, Syrups and concentrates and Instant tea.
The applicant has provided a long list of goods manufactured by him and the ingredients used for the manufacturing of the same. The list is appended below in tabular form.
Vitamins
| SL. No. | Product | Ingredients |
| 1 | Lemon mint | Water, citric acid, malic acid, clouding agent, sucralose, vitamin premix, natural & nature identical flavours (mint, lemon), antifoaming agent |
| 2 | Lemon iced tea | Water, instant tea, citric acid, malic acid, natural flavour (lemon), vitamin premix, sucralose, colour, antifoaming agent |
| 3 | Zesty orange | Water, citric acid, malic acid, nature identical flavour (orange), vitamin premix, sucralose, colour, antifoaming agent |
| 4 | Mango peach | Water, citric acid, malic acid, nature identical flavour (mango, peach), vitamin premix, sucralose, colour, antifoaming agent |
| 5 | Strawberry lemonade | Water, citric acid, malic acid, nature identical flavours (strawberry, lemon), vitamin premix, sucralose, colour, antifoaming agent |
| 6 | Watermelon mint | Water, citric acid, malic acid, natural flavours (watermelon, mint), vitamin premix, sucralose, colour, antifoaming agent |
Cocktails
| SL. No. | Product | Ingredients |
| 1 | Mojito | Water, citric acid, malic acid, clouding agent, sucralose, natural & nature identical flavours (mint, lemon), antifoaming agent |
| 2 | Rose lemonade | Water, citric acid, malic acid, natural & nature identical flavours (rose, lemon), sucralose, colour, antifoaming agent |
| 3 | Lavender honey | Water, citric acid, malic acid, sucralose, natural flavours (lavender, honey), colour, antifoaming agent |
| 4 | Cucumber mint | Water, citric acid, malic acid, sucralose, natural flavours (cucumber, mint), colour, antifoaming agent |
Electrolytes
| SL. No. | Product | Ingredients |
| 1 | Ginger lime | Water, citric acid, malic acid, sodium and potassium salts, natural and nature identical flavour(ginger, lime), sucralose, colour, antifoaming agent |
| 2 | Raw mango | water, citric acid, malic acid, sodium and potassium salts, natural flavour(raw mango), sucralose, colour, antifoaming agent |
| 3 | Orange electrolyte | Water, citric acid, malic acid, sodium and potassium salts, nature identical flavour(orange), sucralose, colour, antifoaming agent |
| 4 | Lemon electrolyte | Water, citric acid, malic acid, sodium and potassium salts, nature identical flavour(lemon), sucralose, clouding agent, antifoaming agent |
Ready To Drink
| Product | Ingredients |
| Lemon iced tea, Peach iced tea, Earl grey iced tea, Lemongrass iced tea | Water, tea decoction, sugar, acidity regulator (INS330,296), sweetening agent (INS955), anti-oxidant (INS331), contains permitted class 2 preservatives (E211), nature identical flavour |
| Orange vitamin water | Water, thickener (INS440), nature identical flavour (orange), acidity regulator (INS330,296), vitamins (A,B3,B6,B12,C,D,E), preservatives (E211), sucralose |
| Litchi vitamin water | water, thickener (INS440), nature identical flavour (litchi), acidity regulator (INS330,296), vitamins (A,B3,B6,B12,C,D,E), preservatives (E211), sucralose |
The above list covers the whole range of products manufactured by the applicant. In the course of hearing the representative of the applicant produced samples of all the above noted products.
4.3 The applicant has placed before us the following questions:
| A) | What is the appropriate classification under GST 2.0 for the following products: |
| • | Non-alcoholic beverage/Iced Tea preparation (HSN 22029020) |
| • | Syrups and beverage concentrate (HSN 21069019) |
| • | Extracts, essences and concentrates of tea (HSN 21012010) |
| B) | Please clarify if the above mentioned HSN Code is correct? If found incorrect, kindly provide the correct HSN Code. |
| C) | Whether these products qualify under Schedule II or III of the new GST rate notifications for food/beverage items? |
| D) | What is the applicable GST rate of the above goods under GST 2.0? |
4.4 The applicant believes that the products under question are processed food/ beverage items intended for human consumption and do not fall under the category of luxury or sin goods. He submits that the products should have the following HSN codes:
| • | Non-alcoholic beverage/Iced Tea preparation (HSN 22029020) |
| • | Syrups and beverage concentrate (HSN 21069019) |
| • | Extracts, essences and concentrates of tea (HSN 21012010) |
The applicant believes that the above noted goods should qualify to be included in Schedule II of the GST Rate Notifications and not under Schedule III. According to him, Non-alcoholic beverage/Iced Tea preparation should be taxed @ 12% and the rest two should be taxed @ 18%.
4.5 The Revenue has opined as follows:
| (i) | Non-alcoholic beverages fall under Schedule III and are taxable at 20 per cent SGST and 20 per cent CGST or 40 per cent IGST under S. No. 2 of the notification, covering tariff items 2202 91 00 and 2202 99 90 described as “Other non-alcoholic beverages [other than those specified in Schedule I]”. |
| (ii) | Iced tea preparation falls under Schedule I and is taxable at 2.5 per cent SGST and 2.5 per cent CGST or 5 per cent IGST under S. No. 136, tariff item 2101 20, described as “Extracts, essences and concentrates of tea or mate, and preparations with a basis of these extracts, essences or concentrates or with a basis of tea or mate”. |
| (iii) | Syrups and beverage concentrates fall under Schedule III and are taxable at 20 per cent SGST and 20 per cent CGST or 40 per cent IGST under S. No. 1 covering tariff items 2202 91 00 and 2202 99 90 described as “All goods (including aerated waters), containing added sugar or other sweetening matter or flavoured”. |
4.6 At the very outset we must make it clear that we have not found any tariff item numbered as ‘22029020’ as mentioned by the applicant against ‘Non-alcoholic beverage/Iced Tea preparation’. The closest possible match for the number in the tariff list is 22029920 which specifies ‘fruit pulp or fruit juice based drinks’. We are reproducing the relevant portion of the Customs Tariff Act, 1975.
| 2202 | WATERS, INCLUDING MINERAL WATERS AND AERATED WATERS, CONTAINING ADDED SUGAR OR OTHER SWEETENING MATTER OR FLAVOURED, AND OTHER NON-ALCOHOLIC BEVERAGES, NOT INCLUDING FRUIT, NUT OR VEGETABLE JUICES OF HEADING 2009 | ||
| 2202 10 | – | Waters, including mineral waters and aerated waters, containing added sugar or other sweetening matter or flavoured: | |
| 2202 10 10 | – – – | Aerated waters | |
| 2202 10 20 | – – – | Lemonade | |
| 2202 10 90 | – – – | Other | |
| – | Other: | ||
| 2202 91 00 | — | Non alcoholic beer | |
| 2202 99 | — | Other: | |
| 2202 99 10 | — – | Soya milk drinks, whether or not sweetened or flavoured | |
| 2202 99 20 | — – | Fruit pulp or fruit juice based drink | |
| 2202 99 30 | — – | Beverages containing milk | |
| 2202 99 90 | — – | Other |
For syrups and beverage concentrates the applicant has suggested tariff item no. 21069019. The relevant portion of tariff heading 2106 is reproduced here:
| 2106 | FOOD PREPARATIONS NOT ELSEWHERE SPECIFIED OR INCLUDED | |
| 2106 10 00 | – | Protein concentrates and textured protein substances |
| 2106 90 | – | Other: |
| — – | Soft drink concentrates: | |
| 2106 90 11 | — — | Sharbat |
| 2106 90 19 | — — | Other |
| 2106 90 20 | — – | Pan masala |
| 2106 90 30 | — – | Betel nut product known as Supari |
| 2106 90 40 | — – | Sugar-syrups containing added flavouring or colouring matter, not elsewhere specified or included; lactose syrup; glucose syrup and malto dextrine syrup |
| 2106 90 50 | — – | Compound preparations for making non-alcoholic beverages |
| 2106 90 60 | — – | Food flavouring material |
| 2106 90 70 | — – | Churna for pan |
| 2106 90 80 | — – | Custard powder |
| — – | Other: | |
| 2106 90 91 | — — | Diabetic foods |
| 2106 90 92 | — — | Sterilized or pasteurized millstone |
| 2106 90 99 | — — | Other |
The suggested tariff item no. for extracts, essences and concentrates of tea is 21012010. The relevant portion of tariff heading 2101 is reproduced as under:
| 2101 | EXTRACTS, ESSENCES AND CONCENTRATES, OF COFFEE, TEA OR MATE AND PREPARATIONS WITH A BASIS OF THESE PRODUCTS OR WITH A BASIS OF COFFEE, TEA OR MATE; ROASTED CHICORY AND OTHER ROASTED COFFEE SUBSTITUTES, AND EXTRACTS, ESSENCES AND CONCENTRATES THEREOF | |
| – | Extracts, essences and concentrates of coffee, and preparations with a basis of these | |
| extracts, essences or concentrates or with a basis of coffee : | ||
| 2101 | – | Extracts, essences and concentrates: |
| 11 | – | |
| 2101 | – | Instant coffee, flavoured |
| 11 10 | — | |
| 2101 | – | Instant coffee, not flavoured |
| 11 20 | — | |
| 2101 | – | Coffee aroma |
| 11 30 | — | |
| 2101 | – | Preparations with basis of extracts, essences, concentrates or with a basis of coffee |
| 12 00 | – | |
| 2101 | – | Extracts, essences and concentrates, of tea or mate, and preparations with a basis of these |
| 20 | extracts, essences or concentrates or with a basis of tea or mate : | |
| 2101 | – | Instant tea |
| 20 10 | — | |
| 2101 | – | Quick brewing black tea |
| 20 20 | — | |
| 2101 | – | Tea aroma |
| 20 30 | — | |
| 2101 | – | Other |
| 20 90 | — | |
| 2101 | – | Roasted chicory and other roasted coffee substitutes, and extracts, essences and |
| 30 | concentrates thereof : | |
| 2101 30 10 | – – – | Roasted chicory |
| 2101 30 20 | – – – | Roasted coffee substitutes |
| 2101 30 90 | — – | Other |
4.7 Now we will proceed to examine the correctness of the tariff item no. suggested by the applicant against each of the products featured in the questions placed by the applicant and rate of tax thereof.
Non-alcoholic beverages:
Under this category the applicant manufactures products like Mojito, Rose lemonade, Lavender honey, Cucumber mint, Orange vitamin water and Litchi vitamin water.
The process of preparation of all the above products is the same. As per the process flowchart supplied by the applicant’s representative, all dry ingredients except citric acid as per table in Paragraph 4.2 are added to required volume of water and are mixed well. Then colour and measured citric acid are added to the mixture and the mixture is heated up to 40 degree centigrade temperature. Then antifoaming element is added and mixed and the mixture is allowed to cool at 30 degree centigrade. Now the liquid mixture is ready for filling into the bottle.
It appears from a combined reading of the above process of preparation and the list of ingredients that the non-alcoholic beverages mentioned in the application for advance ruling do not contain any fruit pulp or fruit juice in it. As such, it cannot be covered by tariff item no. 22029920 of the Customs Tariff Act, 1975 which stands for ‘fruit pulp or fruit juice based drinks’. The said non-alcoholic beverages are covered by tariff heading no. 2202 which stands for ‘Waters, including Mineral Waters and Aerated Waters containing added sugar or other sweetening matter or flavoured, and other non-alcoholic beverages, not including fruit, nut or vegetable juices of Heading 2009’. The specific tariff item no. of these products is 22029990 of the Customs Tariff Act, 1975.
Now we will refer to the relevant entries in the rate schedule of Notification No. 1/2017 – Central Tax (Rate), Dated 28.06.2017, as amended by virtue of Notification No. 09/2025 – Central Tax (Rate), Dated 19.09.2025 in respect of the above noted goods.
Schedule III
| S. No. | Chapter/Hea ding/Sub-heading/Tariff item | Description of goods |
| (1) | (2) | (3) |
| 1. | 2202 10 | All goods (including aerated waters), containing added sugar or other sweetening matter or flavoured |
| 2. | 2202 91 00, 2202 99 90 | Other non-alcoholic beverages [other than those specified in Schedule I of this notification] |
| 3. | 2202 99 90 | Caffeinated Beverages |
| 4. | 2202 | Carbonated beverages of fruit drink or carbonated beverages with fruit juice |
Schedule I
| S. No. | Chapter/Heading/ Sub-heading/Tariff item | Description of goods |
| (1) | (2) | (3) |
| 148. | 2202 99 | Plant-based milk drinks, ready for direct consumption as beverages |
| 149. | 2202 99 10 | Soya milk drinks, whether or not sweetened or flavoured |
| 150. | 2202 99 20 | Fruit pulp or fruit juice based drinks [other than Carbonated Beverages of Fruit Drink or Carbonated Beverages with Fruit Juice] |
| 151. | 2202 99 30 | Beverages containing milk |
On a conjoint reading of the above two tables it appears that the non-alcoholic beverages mentioned in the application for advance ruling will be covered by serial no. 2 of Schedule III. Serial no. 3 of the schedule refers to Caffeinated Beverages only. The exclusion clause of serial no. 2 is also not applicable for the products discussed under this head since the goods specified under serial no. 148, 149, 150 and 151 of Schedule I are not the goods under question. In our considered view, the non-alcoholic beverages as specified by the applicant will come under serial no. 2 of Schedule III and as such will be taxed @ 20% CGST + 20% SGST.
Iced Tea preparation & Extracts, essences and concentrates of tea:
The applicant prepares different kinds of iced tea like Lemon iced tea, Peach iced tea, Earl grey iced tea, Lemongrass iced tea. For preparation of iced tea, 100 gram of water is boiled up to 90 to 95 degree centigrade temperature. Then 6 gram of required tea is added to the boiled water. The mixture is further boiled for 10minutes at a low flame. Then it is allowed to cool down for 5 minutes. The liquid is strained and kept for further cooling. Then the cold preparation is packed.
From the process of preparation and the list of ingredients it appears that the products under the heading ‘Iced Tea preparation & Extracts, essences and concentrates of tea’ will be covered by tariff heading no. 2101 of the Customs Tariff Act, 1975 which stands for ‘Extracts, essences and concentrates, of coffee, tea or mate and preparations with a basis of these products or with basis of coffee, tea or mate……’ More specifically it will be covered by sub-heading no. 210120 and as such it will come under serial no. 136 of Schedule I of Notification No. 1/2017 – Central Tax (Rate) Dated 28.06.2017, as amended by virtue of Notification No. 09/2025 – Central Tax (Rate), Dated 19.09.2025.
So Iced Tea preparation & Extracts, essences and concentrates of tea are to be taxed @ 2.5% CGST + 2.5% SGST.
Syrups and beverage concentrate:
Under this category the products are electrolytes like Ginger lime, Raw mango, Orange electrolyte and Lemon electrolyte. It also includes products like Lemon mint, Zesty orange, Mango peach, Strawberry lemonade and Watermelon mint. These are liquid concentrates which are to be consumed by adding water to the respective concentrate.
So far as the process of preparation and the list of ingredients are concerned the above items are covered by sub-heading 210690 of the Customs Tariff Act, 1975 and specifically will come under tariff item no. 21069019. As such, it is covered by serial no. 145 of Schedule I of Notification No. 1/2017 – Central Tax (Rate), Dated 28.06.2017, as amended by virtue of Notification No. 09/2025 – Central Tax (Rate), Dated 19.09.2025. The products are taxed @ 2.5% CGST + 2.5% SGST.
In view of the foregoing discussion we rule as under:
RULING
1. What is the appropriate classification under GST 2.0 for the following products?
| • | Non-alcoholic beverage and Iced Tea preparation |
| • | Syrups and beverage concentrate |
| • | Extracts, essences and concentrates of tea |
Answer: Tariff item number for non-alcoholic beverages is 22029990. Iced tea preparation will be covered by sub-heading 210120. The same sub-heading is applicable for extracts, essences and concentrates of tea. Tariff item no. 21069019 is applicable for syrups and beverage concentrates.
2. Non-alcoholic beverage / Iced Tea preparation (HSN 22029020) Syrups and beverage concentrate (HSN 21069019) Extracts, essences and concentrates of tea (HSN 21012010) Please clarify if the abovementioned HSN Code is correct?
Answer: The ruling is the same as Question 1 above.
3. Whether these products qualify under Schedule II or III of the new GST rate notifications for food/beverage items?
Answer: Non-alcoholic beverages will qualify for Schedule III (serial no. 2) of Notification No. 1/2017 -Central Tax (Rate), Dated 28.06.2017, as amended by virtue of Notification No. 09/2025 – Central Tax (Rate), Dated 19.09.2025.
Iced tea preparation and extracts, essences and concentrates of tea finds entry in Schedule I (serial no. 136) of the notification ibid.
Syrups and beverage concentrates will qualify for Schedule I (serial no. 145) of the notification ibid.
4. What is the applicable GST rate of the above goods under GST 2.0?
Answer: The non-alcoholic beverages as specified by the applicant will be taxed @ 20% CGST + 20% SGST.
Iced Tea preparation & Extracts, essences and concentrates of tea are to be taxed @ 2.5% CGST + 2.5% SGST.
Syrups and beverage concentrates are taxed @ 2.5% CGST + 2.5% SGST.