The Tamil Nadu Authority of Advance Ruling (AAR) has ruled that 5% GST is payable on rice bran oil and can be classified as edible oil.
The bench of C. Thiyagarajan and B. Suseel Kumar has observed that the rice bran oil, without any additives or mixture of other oils, marketed by the applicant as lamp oil under the trade name ‘Mahara Jyothi’ is classifiable under Tariff Heading 1515 90 40 of the Customs Tariff Act, 1975.
The applicant, M/s. K.T.V. Health Food Pvt. Ltd. is a registered private limited company who are engaged in the process of refining, bleaching and de-odorising the Crude Palm oil and Sunflower oil falling under Chapter 15. The Applicant has stated that they are engaged in the processing and refining of branded edible oils. They have factories at Kodungaiyur and Gummidipoondi in Tamil Nadu.
The Applicant has stated that they procure refined Rice Bran Oil from the market and pack them in 500ml pouches and sell them as lamp oil’ under the trade name ‘Mahara Jyothi’. The Applicant further states that though the refined rice bran oil is marketed as lamp oil under the trade name ‘Mahara Jyothi’, the same would still be classifiable under heading 1515 dealing with the ‘other fixed vegetable or microbial fats and oils (including jojoba oil) and their fractions whether or not refined, but not chemically modified’.
The applicant sought the advance ruling on the determination of correct classification of Lamp oil.
The applicant stated that as per their view, Rice bran oil as such without being mixed with any other oil is to be classified under heading 1515; that the applicable total rate of tax on the said rice bran oil is 5% (CGST 2.5% + SGST 2.5%) as per Sl. No 87 of the Schedule I of the Notification No. 1/2017-Central Tax (Rate), dated 28.06.2017.
The AAR ruled that the product ‘Mahara Jyothi’ is marketed as lamp oil, classification can be done only as per the contents of the item and not as per the end use, unless it is specifically mentioned so in the Tariff.
The AAR opined that as per the provisions of Chapter 15 of the Customs Tariff Act, 1975, Rice Bran Oil is covered under Tariff Heading 1515 90 40.
Ruling Details
Applicant’s Name: K.T.V. Health Food Pvt. Ltd.
Ruling Date: 24.09.2025
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