GST classification of Deepam Oil turns on edible or inedible character, determining whether Chapter 1518 applies.

Tariff classification of Deepam Oil depended on whether the product remained edible or became an inedible preparation. Perfumed Deepam Oil, made by adding perfume to vegetable oil mixtures and meant for lighting lamps, was treated as an inedible mixture of vegetable oils and classified under Chapter Heading 1518, attracting 6% CGST, 6% KGST and 12% IGST. Non-perfumed Deepam Oil declared as not for cooking was also treated as inedible and placed under Chapter Heading 1518 with the same GST rate. Gingely Oil, Palmoline Oil, Rice Bran Oil and their edible mixtures retained their respective Chapter 15 classifications, with edible mixtures falling under Heading 1517 and attracting 2.5% CGST, 2.5% KGST and 5% IGST.

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Issues: (i) Whether perfumed Deepam Oil, prepared by adding perfume to a mixture of Gingely Oil, Palmoline Oil, Rice Bran Oil or any one of those oils and meant for lighting lamps, is classifiable under Chapter Heading 1518 and what rate of GST applies; (ii) Whether non-perfumed Deepam Oil, prepared from a mixture of Gingely Oil, Palmoline Oil, Rice Bran Oil or any one of those oils and declared as not for cooking, is classifiable under Chapter Heading 1518 and what rate of GST applies; (iii) Whether Gingely Oil, Palmoline Oil, Rice Bran Oil and their edible mixtures are classifiable under Chapters 1511, 1515 and 1517 and what rate of GST applies.

Issue (i): Whether perfumed Deepam Oil, prepared by adding perfume to a mixture of Gingely Oil, Palmoline Oil, Rice Bran Oil or any one of those oils and meant for lighting lamps, is classifiable under Chapter Heading 1518 and what rate of GST applies.

Analysis: Addition of perfume converts the edible oil or oil mixture into an inedible preparation. Such inedible mixtures of vegetable oils fall within Chapter Heading 1518. The applicable rate for intra-State supplies is 6% CGST and 6% KGST, and for inter-State supplies 12% IGST.

Conclusion: Perfumed Deepam Oil is classifiable under Chapter Heading 1518 and is taxable at 6% CGST, 6% KGST and 12% IGST.

Issue (ii): Whether non-perfumed Deepam Oil, prepared from a mixture of Gingely Oil, Palmoline Oil, Rice Bran Oil or any one of those oils and declared as not for cooking, is classifiable under Chapter Heading 1518 and what rate of GST applies.

Analysis: A product described as not for cooking is treated as inedible. An inedible mixture or preparation of vegetable oils falls under Chapter Heading 1518. The applicable rate for intra-State supplies is 6% CGST and 6% KGST, and for inter-State supplies 12% IGST.

Conclusion: Non-perfumed Deepam Oil is classifiable under Chapter Heading 1518 and is taxable at 6% CGST, 6% KGST and 12% IGST.

Issue (iii): Whether Gingely Oil, Palmoline Oil, Rice Bran Oil and their edible mixtures are classifiable under Chapters 1511, 1515 and 1517 and what rate of GST applies.

Analysis: Individual Gingely Oil, Palmoline Oil and Rice Bran Oil retain their respective tariff classifications under Chapter 15, and edible mixtures of such oils fall under Chapter Heading 1517. The applicable rate for intra-State supplies is 2.5% CGST and 2.5% KGST, and for inter-State supplies 5% IGST.

Conclusion: Gingely Oil, Palmoline Oil, Rice Bran Oil and their edible mixtures are classifiable under Chapters 1515, 1511, 1515 and 1517 respectively and are taxable at 2.5% CGST, 2.5% KGST and 5% IGST.

Final Conclusion: The ruling accepts the applicant's classification positions in substance and determines the GST rates according to whether the products are edible oils, edible mixtures, or inedible preparations.

Ratio Decidendi: Classification under the tariff turns on the product's composition and edible or inedible character, with edible oils and edible mixtures falling in their respective headings and inedible oil preparations falling under Chapter Heading 1518.

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