Processed cattle feed classified as prepared animal feeding stuff, not oil-cake residue, and treated as GST exempt.
A processed cattle feed product made by mixing groundnut oil cake with broken rice, jaggery, salt and water, then steaming it into a separate marketable form, was treated as a prepared animal feed rather than a mere residue of oil extraction. Applying the General Rules for Interpretation, the chapter note to heading 2309 and the explanatory notes, the product was classified under heading 23099010 because processing altered the character of the original material and it lost the essential characteristics of groundnut oil cake. The supply was therefore held exempt under the relevant GST exemption notifications.
Issues: Whether the product "cattle feed in cake form" is classifiable under heading 2305 as oil-cake/residue of groundnut oil extraction or under heading 2309 as preparations of a kind used in animal feeding, and whether it is exempt from GST.
Analysis: The product was found to be manufactured by mixing groundnut oil cake with broken rice, jaggery, salt and water, followed by processing and steaming into a separate marketable form sold as cattle feed. Heading 2305 covers oil-cake and other solid residues resulting from extraction of groundnut oil, whereas heading 2309 covers prepared animal feeding stuffs obtained by processing vegetable or animal materials to such an extent that they lose the essential characteristics of the original material. Applying the General Rules for Interpretation, the chapter note to heading 2309, and the explanatory notes, the product was treated as a compounded animal feed and not as a mere groundnut oil cake residue.
Conclusion: The product is classifiable under heading 23099010 and is exempt under the relevant exemption notifications.
Final Conclusion: The ruling accepts the applicant's classification and exemption claim, thereby treating the supply of cattle feed in cake form as tax exempt under GST.
Ratio Decidendi: A processed feed product made from oil-cake mixed with other ingredients and marketed as cattle feed is classifiable as a preparation of a kind used in animal feeding, not as a residue of oil extraction, where the processing alters the character of the original material.
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