The GST Appellate Tribunal (GSTAT), Thane Bench, vide Order dated 22.07.2026, dismissed the appeal filed by the Revenue. Accordingly, it was held that M/s. Godrej Tyson Foods Limited had rightly claimed exemption under Serial No. 9 of Notification No. 02/2017-CTR dated 28.06.2017.
Consequently, the demand towards tax, interest, and penalty was held to be unsustainable.
The core dispute centered on whether the taxpayer was entitled to ‘Nil’ GST exemption under Notification No. 02/2017-CT(R) for supplying fresh and frozen poultry products to institutional buyers after removing brand logos (“Godrej Tyson” and “Godrej Real Good”) from unit containers and printing only mandatory corporate details and FSSAI information.
The Revenue argued that retaining the company name, packaging style, and brand names on tax invoices established a brand connection, thereby disqualifying the goods from tax exemption and justifying a confirmed demand of ₹2,26,77,883 along with interest and 100% penalties.
However, the Tribunal held that printing corporate details solely to fulfill statutory traceability requirements under the Food Safety and Standards Act (2006) and Legal Metrology Act (2009) does not constitute using a commercial “brand name”.
Furthermore, the Bench clarified that tax exemption conditions apply strictly to physical goods rather than invoices, and bulk supplies to institutional consumers do not fall under retail “pre-packaged and labelled” commodities. Relying on Supreme Court and High Court precedents, the Tribunal affirmed the first appellate authority’s decision, setting aside all tax demands, interest, and penalties imposed on the assessee.
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