Animal feed classification turns on common parlance: feed ingredients and supplements were excluded from Heading 21-CTA.

Products such as de-oiled rice bran extraction, sesame seed extraction, rape seed extraction and tapioca chips were examined against dictionary meaning, trade understanding, Indian Standard specifications and prior decisions to determine whether they qualified as animal feed under Heading 21-CTA. The materials indicated that the oilcakes and de-oiled rice bran were only ingredients or supplements used in compounded feed, mainly as protein supplements, rather than complete animal feed in common parlance. The solvent-extracted products were also not shown to have been processed to remove residual solvent for animal consumption. Tapioca chips had already been treated in earlier decisions as outside the tariff description. The products were therefore held not to be animal feed and not liable to duty under the heading.

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Issues: Whether de-oiled rice bran extraction, sesame seed extraction, rape seed extraction, rape-seed extraction and tapioca chips were animal feed liable to duty under Heading 21-CTA.

Analysis: The products under appeal were examined against dictionary meaning, trade understanding, Indian Standard specifications, and earlier decisions on animal feed. The materials showed that the oilcakes and de-oiled rice bran were not complete animal feed but only ingredients or supplements used in compounded feed, mainly as protein supplements. The solvent-extracted products were also not shown to have been treated to remove residual solvent so as to make them fit for animal consumption. As to tapioca chips, earlier decisions had already held that they were not animal feed.

Conclusion: The products were not animal feed and were not liable to duty under Heading 21-CTA.

Final Conclusion: The departmental appeals failed, and the Collector (Appeals) was upheld.

Ratio Decidendi: Goods that function only as feed ingredients or supplements, and not as complete animal feed in common parlance, do not fall within the tariff description of animal feed.

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