GST AAR: Rice Bran Oil Classified by Content, Not ‘Lamp Oil’ Use

In re K.T.V. Health Food Pvt. Ltd. (GST AAR Tamilnadu)

In the case of In re K.T.V. Health Food Pvt. Ltd., the Tamil Nadu Authority for Advance Ruling (AAR) addressed the classification of refined rice bran oil marketed under the brand name ‘Mahara Jyothi’ as “lamp oil.” The applicant, a processor of branded edible oils, argued that the product, being unadulterated refined rice bran oil, must be classified under Tariff Heading 1515 90 40, which covers fixed vegetable oils of edible grade and attracts a GST rate. The AAR admitted the application and proceeded to examine the product’s essential character over its intended use. Based on evidence submitted by the applicant, including FSSAI license details and a third-party lab report, the Authority confirmed that the oil met all the stringent quality standards for edible grade rice bran oil as prescribed in the Prevention of Food Adulteration Rules, . The AAR held that the GST classification rules mandate that a product’s identity is determined by its contents and fundamental character, irrespective of how it is advertised or the specific purpose for which it is sold to consumers, unless the tariff explicitly defines classification based on end-use. Conclusively, the AAR ruled that the rice bran oil sold as lamp oil is correctly classifiable under Tariff Heading 1515 90 40, affirming its status as an edible grade fixed vegetable oil for GST purposes.