Gujarat AAR on Castor Oil: Classification and Implications on Refund under Inverted Duty Structure
The present advance ruling (No. GUJ/GAAR/R/2025/30) dated August 12, 2025, has been filed by a company named M/s. Vinayak Agro Industries (Applicant) under Section 91(2) of the CGST / GGST Act, 2017. The company has a registered address at Plot No. 1053/1, Chhatral Kadi Road, Chhatral, Gandhinagar, Gujarat-382279, with GSTIN: 24AAVFV6787GIZA. The applicant is involved in the manufacture of castor oil.
Questions Asked by Appellant:
The appellant, M/s Vinayak Agro Industries, has asked the following questions, seeking the Gujarat Advance Ruling No. GUJ/GAAR/R/2025/30, dated August 12, 2025:
“Question 1. Whether the chapter heading selected for output, i.e., Castor oil [non-edible], is correctly considered under chapter heading 15 at the rate of IGST @ 5%?”
Question 2. Whether the assessee is eligible for the refund of accumulated GST considering the inverted rate structure, considering the notification No. 9/2022-CT(R) dated 13.7.22 & Sr. No. 2 of circular No. 181/13/2022-GST dated 10.11.2022?
Question 3. If a refund of accumulated GST is not allowed, then how can the assessee utilise the accumulated GST due to the inverted rate structure?”
What Did the Ruling Say?
In accordance with the Gujarat Authority for Advance Ruling Goods And Services Tax D/5, Rajya Kar Bhavan, Ashram Road, Ahmedabad-380009, the following answers have been given to the above questions:
Answer 1: The output produced by M/s. Vinayak Agro Industries, i.e., Castor Oil [non-edible], is classifiable under 11SN 1518 and is subject to IGST at 5% in terms of serial no. 90 of schedule I of notification No. 1/2017-11 (Rate), dated 28.6.2017, as amended.
Answers 2 and 3: The advance ruling did not answer the second and third questions, as they have already explained the conclusions above in the ruling.
Citation: M/s. Vinayak Agro Industries; Advance Ruling No. GUJ/GAAR/R/2025/30; 12/08/2025; AAR Gujarat
