Specific tariff entry for inedible oil mixtures prevails over broader vegetable oils classification for fragranced blended oil product.

AAR Karnataka classified a blended edible oil product mixed with fragrance as an inedible mixture or preparation of vegetable oils rather than as a vegetable fat or oil under Schedule I. The ruling treated the product as falling within the more specific Schedule II entry for inedible mixtures or preparations of animal or vegetable fats or oils, because it was manufactured by blending several edible oils and then adding fragrance. As a result, the specific Schedule II classification prevailed over the broader Schedule I description, and the product was taxable at the rate applicable to that Schedule II entry.

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Issues: Whether "Pooja Oil", a blended mixture of edible oils with added fragrance, is classifiable under tariff item 1518 in Schedule I of Notification No. 1/2017-Integrated Tax (Rate) dated 28.06.2017 as vegetable fats and oils, or under Schedule II as an inedible mixture or preparation of vegetable oils, and the rate of GST applicable thereto.

Analysis: The product was found to be manufactured by mixing several edible oils and then blending them with fragrance. On that basis, the resulting product was treated as an inedible mixture. The entry in Schedule I covering vegetable fats and oils was read as applying to modified vegetable oils that remain edible, whereas Schedule II specifically covered inedible mixtures or preparations of animal or vegetable fats or oils. Since the product answered the description of the more specific Schedule II entry, it was held to fall there rather than in Schedule I.

Conclusion: "Pooja Oil" is classifiable under tariff heading 1518 but falls under entry No. 27 of Schedule II of Notification No. 1/2017-Integrated Tax (Rate) dated 28.06.2017 and is taxable at 6% under CGST, 6% under KGST, and 12% under IGST.

Ratio Decidendi: Where a product answers the description of a specific tariff entry for an inedible mixture or preparation, that specific entry prevails over a broader entry covering vegetable fats and oils.

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