TaxTMI 
TaxTMI 
2026 (2) TMI 583
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....ecific provisions. Therefore, unless a mention is particularly made to such dissimilar provisions, a reference to the CGST Act, 2017 would also mean reference to the corresponding similar provisions in the APGST Act, 2017. 3. It is observed that the queries raised by the applicant fall within the ambit of Section 97 of the GST ACT. The applicant attached copies of challans as proof of payment of Rs. 5,000 each for CGST and SGST CPIN Nos. 25103700043866 dated 16.10.2025, and 25103700043866 dated 16.10.2025 respectively, towards the Advance Ruling fee. The Applicant has declared that the questions raised in the application have neither been decided by nor are pending before any authority under any provisions of the GST Act. 4. Brief Facts of the case: 1. The applicant M/s. Sri Venkatarama Gaia Private Limited is engaged in the business of manufacture of 1. Extraction of rice bran edible oil from boiled rice bran /raw rice bran in solvent extraction plant. 2. Manufacture of refined rice bran oil from captive edible oil transferred from solvent plant and also edible oil procured from outside. It also handles by-products like other vegetable oil residues and gunny cuttings. ....
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....il. The FFA is sucked under vaccum and condensed in a Fatty Acid Scrubber. The deodorized oil cooled to room temperature under vaccum and then sent for packaging. The refined rice bran oil is now suitable for human consumption. 6. The process flow chart for edible oil refinery is as under: Images 5. Questions raised before the authority: The applicant sought advance ruling on the following: Q. HSN Code and CGST & SGST rate applicable on spent earth? On Verification of basic information of the applicant, it is observed that the applicant is under Centre jurisdiction i.e, Samalkot Range, Kakinada Division. Accordingly, the application has been forwarded to the jurisdictional officer and a copy marked to the State Tax authorities to offer their remarks as per Sec. 98(1) of CGST /APGST Act 2017. But, so far no remarks are received from the jurisdictional officer. 6. Personal Hearing: The proceedings of Personal Hearing was conducted on 17.12.2025 for which the authorized representative, Sri P Venkateswara Rao, GM Finance have appeared and submitted that previously they used the same HSN code i.e., 3802 90 19 and levied GST @ 18% for both the 'Bleaching earth' an....
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.... send the same to the extraction plant. In the extraction plant we use food grade hexane to extract oil from the bran. Multiple circulation pumps are used to extract every last drop of oil. The oil along with hexane called miscella is sent for distillation to separate hexane from oil and the De-Oiled Bran called DOB along with hexane is sent to the desolventiser toaster. The Miscella first goes through an economiser where it is heated by solvent vapours leaving the toaster to about 70-75 degrees. The evaporated hexane is separated from the miscellla in a separator and miscella is sent further to the heaters to remove the remaining hexane. In the heaters the miscella is heated with steam and evaporated hexane is separated from the miscella in a separator under vaccum. The hexane vapors are then taken to condensers and the liquid hexane condensed is sent back to the parent tank for recirculation. The oil which may still have few traces of hexane is taken to a stripper where all the remianing hexane vapours and taken out of the oil by live steam. The oil which is now clear of hexane is sent to storage tanks. The DOB from the extractor is taken to a Desolventisor toaster to ev....
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....ding expanded clays of heading 6806), andalusite, kyanite and sillimanite, whether or not calcined; mullite; chamotte or dinas earths - bentonite: crude 5% M/O Mines 25081090 Other clays (not including expanded clays of heading 6806), andalusite, kyanite and sillimanite, whether or not calcined; mullite; chamotte or dinas earths - bentonite: other (includes processed and ground) 5% M/O Mines 250820 Other clays (not including expanded clays of heading 6806), andalusite, kyanite and sillimanite, whether or not calcined; mullite; chamotte or dinas earths - decolourising earths and fullers earth: processed (including activated) 5% N/A 8. Discussion and Findings: 8.1 The Authority has carefully examined the facts, documents, samples, photographs, material safety data sheet and Vimta Lab analysis report submitted by the applicant, M/s. Sri Venkatarama Gaia Private Limited. The applicant is engaged in the manufacture of edible oils, including extraction and refining of rice bran oil. The refining process undertaken by the applicant involves multiple stages such as degumming, dewaxing, bleaching, and deodorizing. Each stage is essential to make the oil s....
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....20 - - - Semi -plastic kg. 5% - 2508 30 30 - - - Plastic kg. 5% - 2508 30 90 - - - Other kg. 5% - 2508 40 - Other clays : 2508 40 10 - - - Ball clay kg. 5% - 2508 40 20 - - - Earth clay kg. 5% - 2508 40 90 - - - Other kg. 5% - 2508 50 - Andalusite, kyanite and sillimanite : 2508 50 10 - - - Andalusite kg. 5% - - - - Kyanite : 2508 50 21 - - - - Crude, other than calcined kg. 5% - 2508 50 22 - - - - Processed, other than calcined (washed or ground or screened or beneficiated) kg. 5% - 2508 50 23 - - - - Calcined kg. 5% - - - - Sillimanite : 2508 50 31 - - - - Lumps kg. 5% - 2508 50 32 - - - - Fines (including sand ) kg. 5% - 2508 50 39 - - - - Other kg. 5% - 2508 60 00 - Mullite kg. 5% - 2508 70 00 - Chamotte or dinas earths kg. 5%....