Maize bran is not cattle feed; specific tariff entry for bran applies and GST is payable at five percent.

Maize bran was held not to be cattle feed for the nil-rate entry under Notification No. 2/2017-Central Tax (Rate) because it functions as a by-product or input used in feed preparation, not as feed directly supplied for animal consumption. The specific tariff coverage for bran, sharps and other residues under Notification No. 1/2017-Central Tax (Rate) therefore applied, and the product was taxable at 5% GST under Sr. No. 103A. The ruling turned on the distinction between prepared animal feed and an ingredient or supplement used in its manufacture, with the invoice and product description supporting classification as a feed input rather than finished cattle feed.

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Issues: Whether maize bran manufactured and supplied by the applicant is classifiable as cattle feed eligible for nil rate under Sr. No. 102 of Notification No. 2/2017-Central Tax (Rate) dated 28.06.2017, or whether it falls under Sr. No. 103A of Notification No. 1/2017-Central Tax (Rate) dated 28.06.2017 and attracts GST at 5%.

Analysis: Maize bran is covered under tariff item 23021010 of the Customs Tariff Act, 1975, while Notification No. 1/2017-Central Tax (Rate) separately covers bran, sharps and other residues under Sr. No. 103A. The nil-rate entry in Notification No. 2/2017-Central Tax (Rate) applies to prepared aquatic feed, poultry feed and cattle feed, including allied items such as grass, hay, straw, supplements and additives. On the facts presented, maize bran is a by-product or input used in the manufacture or formulation of cattle feed and is not itself directly fed as cattle feed. The applicant's own description and invoice material supported the view that the product is an ingredient or supplement rather than a finished feed.

Conclusion: Maize bran is not cattle feed for the purpose of Sr. No. 102 of Notification No. 2/2017-Central Tax (Rate); it is correctly classifiable under Sr. No. 103A of Notification No. 1/2017-Central Tax (Rate) and is taxable at 5% GST.

Ratio Decidendi: A raw material or input used in the preparation of animal feed is not equivalent to animal feed itself, and the specific tariff entry for bran prevails over the nil-rate entry meant for prepared feed.

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