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Issues: Whether the proposed "Pooja Oil" is classifiable as an inedible mixture of vegetable oils under Chapter Heading 1518 and, if so, the applicable GST rate.
Analysis: The product was found to be a mixture of different vegetable oils and not a single fixed vegetable oil. It was also not shown to be chemically modified in the manner required for Heading 1516. Heading 1517 was held inapplicable because the goods were marketed and labelled as not for human consumption and were therefore not an edible mixture. On the other hand, Heading 1518 covers inedible mixtures or preparations of vegetable fats or oils or of fractions of different fats or oils of the chapter, not elsewhere specified or included. Applying this classification, the product was placed under Chapter Heading 1518 of the Customs Tariff as applicable to GST. Under Entry No. 96 of Schedule I of Notification No. 9/2025-Central Tax (Rate), goods falling under Chapter 1518 attract 2.5% CGST and 2.5% SGST.
Conclusion: The proposed "Pooja Oil" is classifiable under Chapter Heading 1518 and is chargeable to GST at 5% in total, being 2.5% CGST and 2.5% SGST.
Final Conclusion: The advance ruling answered the classification question against the applicant's lower-rate claim and fixed the product's tax incidence under the later rate notification.
Ratio Decidendi: A mixture of vegetable oils marketed and labelled as not for human consumption, and not chemically modified, is classifiable as an inedible mixture under Chapter Heading 1518, attracting the rate prescribed for that heading in the applicable GST notification.