‘Mahara Jyothi’ Rice Bran Oil Marketed as Lamp Oil Classified Under Edible Oil Tariff Heading with 5% GST: AAR [Read Order]
Although sold as lamp oil, the classification was based on the product’s composition rather than its end use.
![‘Mahara Jyothi’ Rice Bran Oil Marketed as Lamp Oil Classified Under Edible Oil Tariff Heading with 5% GST: AAR [Read Order]](https://images.taxscan.in/h-upload/2025/10/18/2097614-rice-oil-gst-taxscan.webp "‘Mahara Jyothi’ Rice Bran Oil Marketed as Lamp Oil Classified Under Edible Oil Tariff Heading with 5% GST: AAR [Read Order]")
The Tamil Nadu Bench of Authority of Advance Ruling (AAR ) ruled that rice bran oil marketed as lamp oil under the brand name ‘Mahara Jyothi’ was classifiable under Tariff Heading 1515 90 40 as edible-grade fixed vegetable oil and taxable at 5% Goods and Service Tax ( GST ). The applicant,K.T.V. Health Food Pvt. Ltd., located in Kodungaiyur, Chennai, was engaged in...
The Tamil Nadu Bench of Authority of Advance Ruling (AAR ) ruled that rice bran oil marketed as lamp oil under the brand name ‘Mahara Jyothi’ was classifiable under Tariff Heading 1515 90 40 as edible-grade fixed vegetable oil and taxable at 5% Goods and Service Tax ( GST ).
The applicant,K.T.V. Health Food Pvt. Ltd., located in Kodungaiyur, Chennai, was engaged in refining, bleaching, and deodorising crude palm oil and sunflower oil under Chapter 15. The company processed branded edible oils and operated factories in Kodungaiyur and Gummidipoondi, Tamil Nadu.
The applicant had paid the prescribed application fee under Rule 104 of the Central Goods and Service Tax (CGST) and Tamil Nadu Goods and Service Tax ( TNGST ) Rules, 2017, and sought an advance ruling to determine the correct classification of lamp oil.
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It was stated that the applicant procured refined rice bran oil, packed it in 500 ml pouches, and sold it as ‘lamp oil’ under the trade name ‘Mahara Jyothi’. They contended that despite being marketed as lamp oil, the product was classifiable under heading 1515, covering fixed vegetable oils, and was taxable at 5% GST as per Notification No. 1/2017-Central Tax (Rate) dated 28.06.2017.
The application was found admissible under Section 97(2)(a) of the CGST Act, 2017. As no remarks were received from the jurisdictional tax authorities, it was concluded that there were no pending proceedings against the applicant on the issues raised.
The applicant counsel,appeared for the personal hearing and reiterated the earlier submissions.He submitted extracts of Chapter 15 of the Customs Tariff Act, 1975, Notification No. 01/2017-Central Tax (Rate) dated 28.06.2017, and a photo of “KTV True Value” Refined Rice Bran Oil. He stated that rice bran oil fell under Tariff Heading 1515 90 40 with a 5% GST rate and that both ‘True Value’ and ‘Mahara Jyothi’ contained the same edible rice bran oil.
The Members asked if there was any difference in the process, quality, or production location of the two products. The counsel confirmed there was none and said both were made in the same factory. When asked why edible oil was marketed as lamp oil, he explained it was based on customer preference.
The Members requested copies of the trademark licence, FSSAI licence, and lab test report for ‘Mahara Jyothi.’ The counsel agreed and later, through a letter dated 18.08.2025, submitted the required documents along with sales details of both products.
The AAR Authority consisting of B.Suseel Kumar (SGST Member) and C.Thiyagarajan (CGST Member) examined the submissions, documents, and statements made during the personal hearing. It was noted that the applicant was engaged in manufacturing and supplying vegetable oils and lamp oils and had sought a ruling on the correct classification of lamp oil.
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The applicant stated that the product was refined rice bran oil of edible grade, without any change in its essential nature. The Authority referred to Notification No. 1/2017-Central Tax (Rate) dated 28.06.2017 and the Customs Tariff Act, 1975, under which rice bran oil was listed under Tariff Heading 1515 90 40 as a fixed vegetable oil of edible grade.
The Prevention of Food Adulteration Rules, 1955, prescribed quality standards for refined rice bran oil. The third-party lab report provided by the applicant confirmed that the product ‘Mahara Jyothi’ met all parameters for edible-grade oil.
The Authority also noted that the applicant held a valid FSSAI licence for repacking and processing refined rice bran oil, and the licence number appeared on the ‘Mahara Jyothi’ packaging. The Trade Mark certificate for ‘Mahara Jyothi’ covered edible oils, vanaspati, bakery products, and lamp oil. The product packaging mentioned the brand name, description as refined rice bran oil, FSSAI licence number, and details of the manufacturing and packing units.
Based on the evidence, the Authority concluded that ‘Mahara Jyothi’ was refined rice bran oil of edible grade. Although it was marketed as lamp oil, the classification depended on the product’s composition rather than its end use.
Accordingly, the Authority ruled that rice bran oil, without additives or mixtures, marketed as lamp oil under the trade name ‘Mahara Jyothi’, was classifiable under Tariff Heading 1515 90 40 of the Customs Tariff Act, 1975.
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