Cattle feed with groundnut oil cake, rice, jaggery classified under Chapter 2309 as compounded animal feed, not Chapter 2305

AAR Tamil Nadu ruled that cattle feed in cake form manufactured by combining groundnut oil cake with broken rice, jaggery, salt and water is classifiable under Chapter 2309 as "Preparation of a kind used in Animal Feeding - Compounded animal feed" rather than Chapter 2305. The product differs from mere groundnut oil cake due to additional ingredients and manufacturing process involving steaming. Test reports showed varying content percentages of ash, protein, salt, fat, moisture, calcium and phosphorous compared to plain groundnut oil cake. The ruling classified the product under heading 23099010 and confirmed exemption for both intra-state and inter-state supplies under relevant GST notifications.

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Issues Involved:
1. Classification of "Cattle Feed in Cake Form."
2. Availability of exemption under the GST Act.

Detailed Analysis:

1. Classification of "Cattle Feed in Cake Form":
The applicant, M/s. CPR Mill, engaged in manufacturing "Cattle Feed in Cake Form," sought the classification of their product under the SGST Act and CGST Act. The product is made from groundnut oil cake mixed with husked rice, broken rice, jaggery, salt, and water, which is then processed into a solid form. The applicant provided various documents, including test reports and invoices, to support their claim that their product is different from groundnut oil cake alone.

The issue was to determine whether the product should be classified under Chapter Heading 2305 or 2309. According to the Harmonised System of Nomenclature Explanatory Notes 2017, Chapter 23 covers products used in animal feeding. Heading 2305 includes oil-cake and other solid residues from the extraction of groundnut oil, while Heading 2309 includes preparations used in animal feeding that have lost the essential characteristics of the original material.

The Authority examined the manufacturing process and the composition of the product. It was determined that the product is not merely groundnut oil cake but a compounded feed made by adding other ingredients, thus losing the essential characteristics of the original material. Therefore, the product was classified under Chapter Heading 2309 as "Preparation of a kind used in Animal Feeding."

2. Availability of Exemption under the GST Act:
The applicant referred to various notifications under the CGST Act and SGST Act to claim exemption for their product. Specifically, they cited Notification No. 2/2017-Central Tax (Rate) and Notification No. 2/2017-Integrated Tax (Rate), which exempt certain goods from GST.

The Authority confirmed that the product "Cattle Feed in Cake Form" falls under Chapter Heading 2309 and is exempt from GST as per the cited notifications. The product is listed under Sl.No. 102 of Notification No. 2/2017-Central Tax (Rate) and its corresponding notifications for intra-state and inter-state supplies.

Ruling:
The product "Cattle Feed in Cake Form" manufactured by the applicant is classified under Chapter Heading 23099010 and is exempt from GST as per Sl.No. 102 of Notification No. 2/2017-Central Tax (Rate) dated 28th June 2017 and its corresponding notifications for intra-state and inter-state supplies.

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