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Cotton Seed Cattle Feed Taxable at 5% GST: AAR Andhra Pradesh

Case Law Details

TaxGuru Citation
2025 taxguru.in 10169
Case Name
In re V K Industries (GST AAR Andhra Pradesh)
Date of Judgement/Order
Only available for paid members
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In re V K Industries (GST AAR Andhra Pradesh)

M/s V K Industries, located at Adoni, Kurnool, Andhra Pradesh (GSTIN: 37AADFV4507E1ZB), filed an application in Form GST ARA-01 under Section 97(1) of the CGST Act, 2017 and APGST Act, 2017, seeking an advance ruling on the classification and taxability of its proposed new product “Cotton Seed Cattle Feed.” The company paid the prescribed application fee and confirmed that the questions raised were not pending before any authority.

The applicant is engaged in the processing of cotton seeds (HSN 12072100) obtained from ginning plants. The process involves several stages: mechanical cleaning to remove impurities, delinting to separate lint (HSN 14042000), dehulling to extract kernels (HSN 23061090), and expeller pressing to obtain decorticated cotton seed oil cake (HSN 23061010) and raw cotton seed oil (HSN 15122990). Further, residual oil is extracted using food-grade hexane, producing de-oiled cotton seed cake (HSN 23061020) and crude solvent-extracted oil (HSN 15122990). These products attract GST at 5%, while by-products like oil sludge attract 18%. The company’s finished goods are used in the textile, animal feed, and edible oil industries.

Proposed Product: Cotton Seed Cattle Feed

V K Industries proposed manufacturing a new product named “Cotton Seed Cattle Feed,” a ready-to-use feed intended exclusively for cattle. The product is prepared by mixing two raw materials in equal proportion:

1. Decorticated Cotton Seed Oil Cake – Expeller Variety (HSN 23061010)

2. Decorticated Cotton Seed De-oiled Cake – Solvent Extracted Variety (HSN 23061020)

The materials are blended (50:50 by weight), ground to a uniform size of 8 mm, and mixed thoroughly before packaging as finished cattle feed. The mixture provides a balance of oil, fibre, and protein content. The applicant stated that the product is meant only for cattle due to the presence of Gossypol, a toxic compound found in cotton seeds that non-ruminant animals (like poultry or fish) cannot tolerate.

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Author Info

CA Sandeep Kanoi
Qualification: CA in Job / Business
Company: Taxguru Consultancy
Location: Mumbai, Maharashtra
Articles Published: 19,758

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