AAR: non-edible castor oil classed under Chapter 15, IGST 5% via Schedule I serial no.90; subsection 97(2) bars refund issues

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....AAR holds that non-edible castor oil is classifiable under Chapter 15 and, by application of schedule I serial no. 90, attracts IGST at 5%. The Authority, applying HSN explanatory notes, excludes the product from the animal/vegetable fat mixtures provision of the HSN 1518 entry and treats it as a vegetable fat/oil fraction within serial no. 90. Questions on entitlement to refund of accumulated input tax credit arising from an inverted duty structure, and on the permissible utilization of such accumulated credit, are not adjudicated because they fall outside the matters enumerated in subsection 97(2) and therefore are not addressed in this ruling.....