Withdrawal of GST AAR plea on edible rice bran oil after rate clarification: In re Kaleesuwari Refinery Private Limited

Background of the Advance Ruling Application

M/s. Kaleesuwari Refinery Private Limited, a registered assessee under GST (GSTIN: 33AAACK6087A1ZW), approached the Authority for Advance Ruling, Tamil Nadu (AAR) seeking clarity on the classification and GST rate applicable to a new edible oil product proposed to be launched in the market.

The assessee is engaged in the business of manufacturing and marketing edible oils and various food products. In the ordinary course of expansion, the assessee proposed to introduce a product branded as “Dheepam Lite”, and sought to ensure that the GST classification and rate adopted at launch aligned with the statutory framework.

The application for advance ruling was filed:

  • Online on 19.06.2025 under ARN: AD3306250591553,
  • With the physical copy received by the AAR office on 26.06.2025,
  • After remittance of application fees of Rs. 5,000/- each under CGST and SGST, in terms of sub rule (1) of Rule 104 of the CGST Rules, 2017 and the corresponding TNGST Rules.

The assessee triggered the ruling mechanism under Chapter XVII of the CGST/TNGST enactments (advance ruling provisions) to avoid any future dispute on HSN classification or rate of tax for this new product.

Product Description and Regulatory Position

Nature and Composition of “Dheepam Lite”

The assessee described the proposed product in detail as part of the application:

  • Single-ingredient oil: “Dheepam Lite” is made solely from refined rice bran oil (RBO).
  • No blending: It is not a composite or blended oil; there is no mixing with any other vegetable oils or substances.
  • Purity of ingredients: The product is composed of 100% refined rice bran oil, without:
    • Synthetic fragrances,
    • Infusions,
    • Other additives.

Labelling and Consumer Disclosure

The assessee undertook to adopt completely transparent labelling practices, specifically stating on the packaging that:

  • It is not a blended oil,
  • It comprises 100% refined rice bran oil,
  • It contains no fragrance or infusion of any nature.

This was highlighted as an important aspect, ensuring that consumers are fully aware of the edible and unadulterated nature of the product.

FSSAI Compliance and Edible Use

Along with the application, the assessee annexed:

  • The FSSAI license number, and

  • The product label evidencing that:

    1. FSSAI approval had been duly obtained,
    2. The product had been categorized and graded as edible oil,
    3. It carried the standard green vegetarian symbol, and
    4. It was fit and intended for cooking and other edible uses.

Thus, from a food safety and regulatory standpoint, “Dheepam Lite” was to be marketed and consumed strictly as an edible cooking oil, not as a lamp oil or any other non-edible variant.

Questions Raised Before the AAR

In this factual matrix, the assessee requested the AAR to pronounce an advance ruling on the following specific issues:

  1. HSN classification

    • Whether the HSN code adopted for rice bran oil (refined) is correct and in consonance with the applicable GST tariff classification norms?

  2. Applicable GST rate

    • Whether the supply of the said edible rice bran oil is liable to GST at 5% or at 12%?

These questions were raised to obtain certainty on: