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Issues: Whether the storage loss in Low Sulphur Heavy Stock was liable to be condoned beyond 0.05% and whether duty demand should be restricted accordingly.
Analysis: The product was found to be handled as a hot fluid at about 70 C, transported in insulated tank lorries, and difficult to measure accurately by dipping. The earlier allowance of only 0.05% was considered to have proceeded on the assumption that the product remained semi-solid at normal temperature, without giving due weight to the actual conditions of handling and the human factor involved in measurement.
Conclusion: The acceptable storage loss was fixed at 0.25% as normal loss. The appeals were allowed in part, and in the remaining cases duty was restricted to the balance after allowing 0.25% as due to normal causes.