Brindavan Agrotech Private Limited ., In re

The case involves a request from the appellant to set aside an Advance Ruling (AR) from 21.02.2023 regarding the classification of Fortified Rice Kernel (FRK). The appellant contends that it should be classified under Chapter Heading 1103 of the Customs Tariff Act. - The ruling considers the relevant provisions of the Customs Tariff Act, specifically Note 2 of Chapter 11, which states the conditions under which products from the milling of cereals can be classified. - The manufacturing process of FRK involves multiple steps: converting rice to flour, blending with vitamins and minerals, and extrusion to form pellets. The order concludes that while the initial milling process might classify it under Chapter 11, subsequent processes fall outside its scope. - Notifications related to GST rates are also examined, notably the intent to classify FRK under Chapter 19 based on the Government's recommendations and amendments. - The ruling concludes that FRK is classified under Chapter 19, sub-heading 1904 90 00, since its preparation exceeds the limits of milling defined in Chapter 11. The appellant is entitled to benefit from the applicable notifications, provided they meet the specified conditions. Overall, the case underscores the importance of process definitions and government intent in classifying goods under the GST framework.