Tapioca Flour attracts 5% GST under Residues and Waste from Food Industries: AAR upholds Earlier Ruling [Read Order]
The applicant’s own description of the product categorically confirms it is a waste by-product from starch extraction, unsuitable for human consumption, and used primarily as animal fodder or in industrial applications, observed the bench.
![Tapioca Flour attracts 5% GST under Residues and Waste from Food Industries: AAR upholds Earlier Ruling [Read Order]](https://images.taxscan.in/h-upload/2025/07/30/2070887-tapioca-powder.webp "Tapioca Flour attracts 5% GST under Residues and Waste from Food Industries: AAR upholds Earlier Ruling [Read Order]")
In a recent ruling, the Tamil Nadu Authority for Advance Ruling ( AAR) held that tapioca flour derived from wet tapioca waste is classifiable under Chapter 23 of the Customs Tariff, which deals with "Residues and waste from the food industries; prepared animal fodder", and thereby attracts 5% GST. An application filed by V S Trading, a dealer engaged in the supply...
In a recent ruling, the Tamil Nadu Authority for Advance Ruling ( AAR) held that tapioca flour derived from wet tapioca waste is classifiable under Chapter 23 of the Customs Tariff, which deals with "Residues and waste from the food industries; prepared animal fodder", and thereby attracts 5% GST.
An application filed by V S Trading, a dealer engaged in the supply of tapioca-based products. The AAR has further refused to rectify the ruling, holding that no error apparent on record exists. The applicant submitted that the product in question is manufactured from inferior quality tapioca tubers, which are dried and crushed into flour. This flour is not suitable for human consumption and is typically used for animal feed and for manufacturing adhesives.
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In addition, the applicant mentioned that the product is marketed under the name kappi, which is a residue obtained after grinding dried tapioca waste, and that this end-product is also exclusively sold for livestock use.
The AAR, in its earlier ruling, had already held that such tapioca flour, not fit for human consumption and not used in the food industry, rightly falls under Tariff Item 2303 10 00 residues of starch manufacture and similar residues. The applicable GST rate for such classification is 5%, and not the nil rate applicable to food-grade flour.
In the application for rectification, V S Trading argued that the product should not have been classified as residue or waste, but as a primary product eligible for nil GST, presumably under Chapter 11, which includes flour and meal of the milling industry.
However, the AAR rejected this contention, stating that the applicant’s own description of the product categorically confirms it is a waste by-product from starch extraction, unsuitable for human consumption, and used primarily as animal fodder or in industrial applications.
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The AAR rejected the rectification request by citing Section 98(2) of the CGST/TNGST Acts, 2017 and pointing out the cohesiveness of the facts presented and the absence of any error or omission in the earlier finding.
The bench of B. Susheel Kumar ( SGST Member) and Balakrishna S. (CGST member) noted that the facts presented by the applicant constitute the basis upon which advance rulings are made, and in this instance, the evidence amply supported the classification under Chapter 23. As a result, no correctable error or legal misunderstanding could be found.
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