Page 132 - GSTL_27th August 2020_Vol 39_Part 4

458 GST LAW TIMES [ Vol. 39
new unit at 112, Industrial Area No. 1 Dewas for manufacture of the finished
product “Preparation of a kind used in Animal Feeding - Bio Processed Meal”
which will be used for animal feeding only. The applicant also submitted a de-
tailed process as how the raw material soyabean meal will undergoes various
processes in various section like inoculation and missing section, bio-processing
section/fermentation section, drying section, milling and packaging section to
achieve the goal of manufacturing the finished product. The applicant submitted
the basic quality addition made to the raw material to obtain the final product
and the changes takes place in the raw material has also been categorically men-
tioned in para 15(c) of the application of the applicant which reads as under :

S. Properties Soyabean meal Bio-Processed
No. Soyabean meal
1. Anti-nutritional factor.
c. Glycinin 4-6 <0.5
d. B. Conglycinin 2-3 <0.2
2. P.H. 6.5-7 4.5-5.0
3. Lactic Acid 0.03-0.05 4-4

The applicant further in 15(f) of the application has categorically submit-
ted the scientific base in detail to prove the fact that the end product will be used
for Preparation of a kind used in Animal Feeding - bio processed meal. Basically
the process uses biotechnology to digest protein structure to smaller molecular
weight, increase efficiency digestion and absorption. It also breaks down and
reduces antigens and antnutrient substance due to fermentation. The applicant
has also emphasised that the finished product is a high quality soya protein
source of animal such as animals in Aquatic feed including shrimp feed, poultry
feed, cattle feed and pig feed. It focuses on the use of protein sources in animal
feed by replacing fish meal, skim milk, milk replacer. The applicant also declared
that the fermented soya protein can be used in various kind of animal feed such
as poultry, aqua, cattle, pig feed etc.
The applicant finally declared that the product Preparation of a kind used in
Animal Feeding - Bio Processed Meal will only be used for animal feeding and not for in
other purpose.
11.9 From the above discussion and as per declaration of the Applicant
that the said product i.e. Bio Processed Meal is only for specific use of Animal
Feed, it is clear to us that the finished product being manufactured by the appli-
cant will only be used for animal feeding and not for any other purpose and thus
it should fall under Chapter Heading 2309 90 90. We hold it accordingly.
11.10 Serial No. 102 of Notification No. 2/2017-C.T. (Rate), dated 28-6-
2017 and corresponding notification issued under MPGST Act speaks that the
goods Aquatic feed including shrimp feed and prawn feed, poultry feed & cattle
feed, including grass, hay & straw, supplement & husk of pulses, concentrates &
additives, wheat bran & de-oiled cake falling under Chapter Headings 2302,
2304, 2305, 2306, 2308, 2309 are exempted from payment of GST.
11.11 In view of the aforesaid discussion the applicant is eligible to
avail exemption on their finished products “Preparation of a kind used in Animal
Feeding - Bio Processed Meal” from payment of GST under Notification No. 2/2017-
C.T. (Rate), dated 28-6-2017 and corresponding notification issued under MPGST
Act. We hold accordingly.
GST LAW TIMES  27th August 2020  132