Maize bran classification: bran by-product used in cattle feed is taxable, not exempt as cattle feed.

Maize bran was held not to qualify as cattle feed for the NIL-rate exemption because it is a bran by-product used as an ingredient or supplement in cattle feed, not feed directly administered to cattle. The ruling treated the product as falling within the specific bran tariff entry under Heading 2302 rather than the exemption entry for cattle feed, relying on the applicant's own description and invoice evidence showing supply to cattle feed manufacturers. As a result, maize bran was classified under the residual bran entry and made taxable at 5% GST.

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Issues: Whether maize bran is classifiable as cattle feed eligible for NIL rate under the exemption entry, or whether it falls under the residual bran entry taxable at 5% GST.

Analysis: The product was examined in the context of the tariff entry for bran under Heading 2302 and the competing exemption entry for cattle feed. Maize bran was found to be a by-product used as a supplement or ingredient in cattle feed, not cattle feed by itself. The materials placed on record, including the applicant's own description and invoice, showed that the goods were supplied as an input to manufacturers of cattle feed and not as feed directly administered to cattle. On that basis, the product answered the description of bran under the specific tariff entry and did not satisfy the cattle feed exemption entry.

Conclusion: Maize bran is not covered by the NIL-rate cattle feed entry and is correctly classifiable under Entry 103A of Notification No. 1/2017-Central Tax (Rate), attracting GST at 5%.

Ratio Decidendi: Where a product is a bran by-product used as an ingredient or supplement in cattle feed, it is not treated as cattle feed for exemption purposes and is taxable under the specific bran entry.

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