Processed product classification turns on finished character and intended use, not a single raw material.

For sales tax classification, the finished product must be identified by its processed character, composition and intended market use, not by one underlying raw material. A product marketed as ToxiwinES or Toxin Binder was found to undergo purification, grinding, pulverising and addition of feed additives, and it was certified and sold as an animal feed supplement. On that basis, the court held that the product fell under poultry feed in Entry 48 of Schedule I of the Gujarat Value Added Tax Act, 2003, rather than minerals and ores in Entry 51 of Schedule II.

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Issues: Whether the product marketed as ToxiwinES or Toxin Binder was classifiable as poultry feed under Entry 48 of Schedule I of the Gujarat Value Added Tax Act, 2003, or as minerals and ores under Entry 51 of Schedule II of that Act.

Analysis: The product was found to undergo several processing stages after extraction of zeolite, including purification, grinding, pulverizing and addition of feed additives such as acids, minerals, vitamins, amino acids and other supplements. The record showed that the final commodity was marketed as an animal feed supplement and was certified by the Director of Animal Husbandry as such. The mere presence of zeolite as a main ingredient did not control classification, because the relevant question was the character of the finished product in its marketable form and its intended use as animal feed.

Conclusion: The product was correctly held to fall under Entry 48 of Schedule I as poultry feed and not under Entry 51 of Schedule II as minerals and ores.

Ratio Decidendi: For sales tax classification, the finished product must be classified according to its processed character, composition and intended use in the market, and not merely by reference to one underlying raw material.

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