In Advance Ruling No.01/AAR/2023-AAR- 'Mahara Jyothi Oil' classified as edible RBD Palmolein under tariff heading 1511 90 20: Tamil Nadu AAR
Members N. Usha (SGST) & R. Gopalsamy (CGST) [27-03-2023]

Read Order: In Re: K T V HEALTH FOOD PVT LTD

LE Correspondent

Chennai, May 10, 2023:  The Tamil Nadu bench of the Authority for Advance Rulings (AAR) has ruled that ‘Mahara Jyothi oil’, which is an edible RBD Palmolein without any additives or mixture of other oils, is classifiable under 1511 90 20.

KTC Health Food Pvt. Ltd. (applicant), engaged in the processing and refining of healthy branded edible oils for more than three decades, had proposed to introduce their product, RBD Palmolein, as ‘Mahara Jyothi’, intended to be marketed as lamp oil for use in Hindu prayer halls. The applicant had sought a ruling as to the correct classification of Oil which is marketed by them as Mahara Jyothi (lamp oil).

The Authority examined the submissions of the applicant that the manufacturing process and the essential nature of the product remained the same as their edible RBD Palmolein, branded as ‘Roobini’. They clarified that no perfumes or additives were added to Mahara Jyothi, and it continued to be edible RBD Palmolein. They further submitted that the packaging of Mahara Jyothi included information such as ‘Refined Palmolein’ and ‘Edible Vegetable Oil’ along with the FSSAI license number. Based on the applicant's submissions, the Authority held that classification of the product should be based on its contents rather than its end use unless specifically mentioned, and ruled that Mahara Jyothi is nothing but edible RBD Palmolein, classifiable under tariff heading 1511 90 20, in accordance with Chapter 15 of the Customs Tariff Act.

The Authority noted the previous AAR ruling, M/s Sri Kanyakaparameshwari Oil Mills [LQ/AAR(GST)/2019/195], wherein it was held that Deepam Oil, which was an inedible mixture of Gingelly oil, Palmolein oil, and rice bran oil used as a lighting lamp for God, was classified under Chapter Heading 1518. However, the Authority opined that the ruling of the AAR in the aforementioned case was distinguishable, as in the present case, Mahara Jyothi oil was neither a mixture of oils, nor was it inedible.