Reversal of input tax credit in proportion to exempt supply: specificity of show-cause notice required; order set aside, fresh proceedings allowed wit...
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A proposed mixture of vegetable oils marketed as "Pooja Oil" and labelled "Not for Human Consumption" was classified under Chapter Heading 1518 because headings 15.07 to 15.15 cover single oils, heading 15.16 applies only to chemically transformed products, and heading 15.17 is limited to edible mixtures. The Authority treated the declared non-human use and marketing description as decisive, and rejected theoretical edibility as irrelevant. On that classification, the product fell within Entry No. 96 of Schedule I of Notification No. 9/2025-Central Tax (Rate) and was taxable at 5%, comprising 2.5% CGST and 2.5% SGST.
A proposed mixture of vegetable oils marketed as "Pooja Oil" and labelled "Not for Human Consumption" was classified under Chapter Heading 1518 because headings 15.07 to 15.15 cover single oils, heading 15.16 applies only to chemically transformed products, and heading 15.17 is limited to edible mixtures. The Authority treated the declared non-human use and marketing description as decisive, and rejected theoretical edibility as irrelevant. On that classification, the product fell within Entry No. 96 of Schedule I of Notification No. 9/2025-Central Tax (Rate) and was taxable at 5%, comprising 2.5% CGST and 2.5% SGST.
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