Specific tariff classification prevails for bee feed, attracting 18% GST and excluding animal feed treatment.

BEE-PRIME FEED was treated as artificial honey under heading 1702.90 rather than animal feed under heading 2309, because its composition was predominantly refined sugar with glucose and additives, and the more specific tariff description prevailed over the general feed heading. As a result, the product attracted GST at 18% under the Schedule III entry covering artificial honey and related goods. The authority also held that the question concerning specific product details fell outside advance ruling jurisdiction and could not be answered on merits.

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Issues: (i) Whether the product "BEE-PRIME FEED" is classifiable under heading 1702 as artificial honey or under heading 2309 as animal feed; (ii) What is the applicable GST rate on the product if classifiable under heading 1702; (iii) Whether the question relating to specific product details falls within the advance ruling jurisdiction.

Issue (i): Whether the product "BEE-PRIME FEED" is classifiable under heading 1702 as artificial honey or under heading 2309 as animal feed.

Analysis: The product was found to contain refined sugar as the predominant ingredient, along with glucose and additives, and to be a mixed supplementary feed used for bees. Chapter 23 and heading 2309 were held inapplicable because the product was not shown to be a prepared animal fodder of the kind covered there. Heading 1702 specifically covers other sugars and artificial honey, including mixtures based on sucrose or glucose prepared to imitate natural honey. Applying the principle that a more specific description prevails over a general one, the product was treated as artificial honey.

Conclusion: The product is classifiable under heading 1702.90 and not under heading 2309.

Issue (ii): What is the applicable GST rate on the product if classifiable under heading 1702.

Analysis: The rate entry for heading 1702 in Schedule III of Notification No. 01/2017-Central Tax (Rate) covers other sugars, including glucose, sugar syrups not containing added flavouring or colouring matter, artificial honey, whether or not mixed with natural honey, and caramel. Since the product was classified as artificial honey under heading 1702, it attracted the rate prescribed for that entry.

Conclusion: The applicable GST rate is 18%.

Issue (iii): Whether the question relating to specific product details falls within the advance ruling jurisdiction.

Analysis: The authority held that the third question was not a question covered by the statutory scope of advance ruling under the applicable provisions, and therefore could not be answered on merits within that jurisdiction.

Conclusion: The question is beyond the advance ruling jurisdiction.

Final Conclusion: The product was held classifiable as artificial honey under heading 1702.90 and liable to GST at 18%, while the remaining question was declined for want of jurisdiction.

Ratio Decidendi: Where a product's composition and use show it answers a specific tariff entry more closely than a general competing entry, classification must follow the most specific description, and the rate applicable to that entry follows accordingly.

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