Heritage Foods Limited has secured a major victory in a long-standing tax dispute with the GST Department of Andhra Pradesh. The Supreme Court of India has dismissed a Special Leave Petition (SLP) filed by the department, thereby upholding the company's position regarding the applicable GST classification on flavoured milk.

In a regulatory filing dated 21 July 2025, the company disclosed that the apex court has backed the earlier decision of the Andhra Pradesh High Court in Writ Petition No. 27108/2021, which ruled that flavoured milk should be classified under HSN Code 04029990, attracting 5% GST, instead of 12% GST under HSN 22029990.

🧾 Refund of ₹4.53 crore expected

As a direct result of this favourable judgment, Heritage Foods is now entitled to a refund of ₹453.44 lakh, which had earlier been paid under protest. The refund break-up is as follows:

• IGST: ₹17.05 lakh

• CGST: ₹218.20 lakh

• SGST: ₹218.20 lakh

This refund pertains to the period from July 1, 2017, to October 31, 2021, during which the company had paid GST at the higher 12% rate while contesting the classification.

✅ Classification dispute conclusively resolved

The dispute revolved around whether flavoured milk should be treated as a dairy product (taxable at 5%) or as a non-alcoholic beverage (taxable at 12%). Multiple legal forums have now ruled in favour of the company’s position.

Heritage Foods confirmed that it has aligned its GST tariff classification accordingly and has begun actions to initiate refund claims with the appropriate tax authorities. The company emphasized that there were no penalties, restrictions, or non-compliances noted in the Supreme Court’s decision.

🏛 Statement from the company

In the official disclosure signed by Umakanta Barik, Company Secretary & Compliance Officer, the company affirmed:

“The classification of Flavoured Milk under HSN Code 04029990, attracting 5% GST, has been conclusively upheld and supported by the judicial pronouncement of the Hon’ble Supreme Court of India.”

This marks a significant financial and legal relief for the company, with no further liabilities expected on this matter.

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