Composite product classification turns on the finished commodity, not individual ingredients; whipped topping fell under the residuary schedule.

A composite manufactured product must be classified on the basis of the finished commodity as marketed, not on the separate character of its ingredients. Rich's Whip Topping, made through processes such as emulsification, pasteurization, homogenization, chilling and ageing, emerged as a distinct commercial product and could not be treated as a mere raw material or industrial input under entry 100(4) of Schedule IV. It therefore fell outside that entry and was taxable under the residuary Schedule V.

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Issues: Whether the product "Rich's Whip Topping" was a raw material or industrial input falling under entry 100(4) of Schedule IV to the Andhra Pradesh Value Added Tax Act, 2005, or whether it was classifiable under the residuary Schedule V.

Analysis: The product was found to be a composite manufactured commodity made from several ingredients, including vegetable fat, sugar, emulsifiers, stabilizers and flavouring substances, after processes such as emulsification, pasteurization, homogenization, chilling and ageing. On that basis, it could not be treated as a mere raw material or industrial input in its natural and unprocessed form. The fact that some individual ingredients may separately answer entry 100(4) did not control the classification of the finished product. Once the ingredients were combined, a distinct commercial commodity emerged, and the product did not fit within entry 100(4). Since Schedule V applied to all goods not covered by the specified schedules, the product fell within the residuary entry.

Conclusion: The product was not classifiable under entry 100(4) of Schedule IV and was taxable under Schedule V at the residuary rate.

Ratio Decidendi: Where the manufacture of a composite product results in a distinct commercial commodity, classification must be made on the finished product as marketed, and not on the character of its individual ingredients.

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