In re Vippy Industries Ltd. (GST AAR Madhya Pradesh)
In a revised order AAR Madhya Pradesh Held that The product Preparation of a kind used in Animal Feeding – Bio Processed Meal’ is entitled to classify under HS code 23099090 and therefore entitled to clear the said goods for specific use of Animal Feeding without payment of GST under serial no. 102 of the Notification No. 02/2017-CT(Rate) dated 28.06.17 and corresponding notification issued under MPGST Act.
Read Original Order dated 02.01.2020
FULL TEXT OF ORDER OF THE AUTHORITY OF ADVANCE RULING, MADHYA PRADESH
PROCEEDINGS
(Under sub-section (4) of Section 98 of Central Goods and Service Tax Act, 2017 and the Madhya Pradesh Goods & Service Tax Act, 2017)
(Rectified Order of No. 01/2020 dated 02.01.2020 under Section 102 Central Goods and Service Tax Act, 2017 and Madhya Pradesh Goods and Service Tax Act, 2017)
1. M/s Vippy Industries Ltd.,/Plot No. 112], Industrial Area. A.B. Road, Dewas (hereinafter referred to as the applicant) [will manufacture finished products viz. “Preparation of a kind used in Animal Feeding Bio Processed Meal” which will be used for animal feeding only]. The Applicant is having a GST registration with 23AABCV1297N3ZY effected from 30.03.2019.
2. The applicant has sought advance Ruling on the confirmation of classification of the product “Preparation of a kind used in Animal Feeding Bio Processed Meal” falling under HS Code 23099090. The applicant has provided the following process for manufacture of said product. The advance Ruling in this matter was pronounced on 02.01.2020. The order, however, suffers from certain errors, as pointed out by the applicant vide their application dated 28/29.01.2020 and dated 10.02.2020. that are apparent on the face of the records. They need to be rectified. The Authority therefore proceeds to examine the facts as pointed by the applicant
3. Brief Facts of the Case:
3.1 Soybean meal (raw material) with 12% moisture is conveyed to buffer tank after removal of metal impurities. All raw materials after measurement are sent into batch mixer for mixing, and then mix with liquid bacteria/Enzymes in the continuous mixer through a variable frequency screw conveyor which regulates its flow rate. Moisture content is adjusted to around 40% -50% in the continuous mixer. Finally Soybean meal after inoculation and mixing is delivered to fermentation section.
3.2 After Inoculation Soybean meal through conveying equipment is transported to fermentation bed & kept there for 60-72 hours. The thickness of the material deck is designed to be within 75-150mm range and may be adjusted according to actual circumstances. The processing capacity of fermentation bed will also be adjusted by changing the thickness of material layer. During the fermentation process agitation of material may be needed according to the process design. After the fermentation process the material is discharged and collected by a belt conveyor to the drying section. In the conveying process, some material may be fall off the conveyor and needs to be cleaned manually.
3.3 The fermented Soybean meal is then pre-dried by a tube bundle dryer to around 20 25% moisture content and then enters live drying tower for further drying at relatively low temperature. The retention time inside the drying tower can be adjusted by adjusting the thickness of the material deck in each tray of the drying tower. The hot air in the drying tower is utilized repeated in each layer and then achieves energy efficiency and maintains desirable colour of the finished product.
3.4 The dried meal is then transported through cold air transfer to pulveriser for grinding to 1mm size and is finally transported through pneumatic transfer to finished product buffer tank and then for measurement and packing.
3.5 The end product will be sold for use as Aquatic feed including shrimp feed, poultry feed. Cattle feed & Pig feed in domestic and Export market. This product will be used for consumption of Aquatic feed including shrimp feed, poultry feed, Cattle feed & Pig feed etc.
3.6 Bacteria Enzymes are mixed in to soybean meal & left for fermentation for 60 to 72 hours (approx.)During this time following changes takes place in the meal.
