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Issues: Whether the product "Rava Idli Mix" is classifiable under tariff heading 1106 or tariff heading 2106, and the consequential rate of GST applicable to the product.
Analysis: The product was found to be a mixture of flours of cereals and pulses with spices and other ingredients, and not a single-ingredient flour of the kind contemplated by Chapter 11. Chapter 11 was held inapplicable because the product did not satisfy the relevant note-based conditions for products of milling industry and did not correspond to the limited description of heading 1106. The circular relied upon for chhatua or sattu was held to concern flour of pulses with only very small additives, and not a mixed preparation of cereals, pulses and other ingredients. Applying Rule 3(a), the more specific description was held to be heading 2106 as a food preparation not elsewhere specified or included, making Rule 3(b) unnecessary.
Conclusion: The product is classifiable under tariff heading 2106 and not under heading 1106, and it attracts GST at 18%.
Final Conclusion: The ruling settles that the impugned product is a miscellaneous edible preparation falling under heading 2106, with tax liability determined accordingly.