Maize bran classification for GST: product treated as bran, not cattle feed, and taxed at 5%.

Maize bran specifically classifiable under tariff item 23021010 was held to be distinct from cattle feed, so the nil-rate exemption for cattle feed did not apply. As the product was described in the record as a supplement or ingredient used in cattle feed, and the applicant's invoices identified it as wet bran, the specific rate entry for bran and other residues applied. The supply was therefore chargeable to GST at 5% under Entry 103A of Notification No. 01/2017-Central Tax (Rate).

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Issues: Whether maize bran supplied by the applicant is classifiable as cattle feed eligible for nil rate of tax under Notification No. 02/2017-Central Tax (Rate), or whether it falls under Entry 103A of Notification No. 01/2017-Central Tax (Rate) as bran taxable at 5%.

Analysis: The product was examined in the light of the tariff entry for bran under Chapter 23 of the Customs Tariff and the GST rate notifications issued under the CGST regime. Maize bran was found to be specifically covered by tariff item 23021010 and to be a distinct product from cattle feed. The material on record showed that maize bran was described as a supplement or ingredient used in cattle feed, and the applicant's own invoices classified it as wet bran rather than cattle feed. On that basis, the exemption entry for cattle feed was held inapplicable, while the specific entry for bran and other residues under Entry 103A applied.

Conclusion: Maize bran is not eligible for nil-rate treatment as cattle feed and is chargeable to GST at 5% under Entry 103A of Notification No. 01/2017-Central Tax (Rate).

Ratio Decidendi: Where a product is specifically identifiable as bran under the tariff and is used only as an ingredient or supplement in cattle feed, it cannot be treated as cattle feed for the purpose of a nil-rate exemption notification.

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