Compounded animal feed classification under Chapter 2309 applies to processed cattle feed, securing GST exemption.

Cattle feed made by mixing groundnut oil cake with rice, jaggery, salt and water is classifiable as compounded animal feed under Chapter Heading 2309, not as groundnut oil cake under Chapter Heading 2305. Because the processed mixture is sold as cattle feed and has lost the essential character of the original oil-cake residue, the General Rules for Interpretation and tariff notes support classification under the animal-feed heading. The product is classifiable under sub-heading 23099010 and is exempt under the relevant GST exemption notifications for intra-State and inter-State supplies.

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Issues: Whether cattle feed in cake form, manufactured by mixing groundnut oil cake with rice, jaggery, salt and water, is classifiable under Chapter Heading 2305 as groundnut oil cake or under Chapter Heading 2309 as a preparation of a kind used in animal feeding, and whether it is exempt from GST.

Analysis: Chapter 2305 covers oil-cake and other solid residues resulting from extraction of groundnut oil. Chapter 2309 covers preparations of a kind used in animal feeding, including products obtained by processing vegetable materials to such an extent that they lose the essential characteristics of the original material. The product here was not mere groundnut oil cake; it was a processed mixture of groundnut oil cake with other ingredients, was sold as cattle feed, and differed in composition from the raw material. Applying the General Rules for Interpretation and the tariff and explanatory notes, the product was held to be a compounded animal feed falling under Chapter Heading 2309.

Conclusion: The product is classifiable under Chapter Heading 23099010 as compounded animal feed and is exempt under the relevant exemption notifications for intra-State and inter-State supplies.

Ratio Decidendi: A processed feed preparation made from oil-cake together with other ingredients, which has lost the character of the original residue and is used as animal feed, is classifiable under Chapter 2309 and not under Chapter 2305.

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