Classification of hardened vegetable oils turns on essential nature and trade identity, keeping them under the specific tariff entry.

Chemically hardened or hydrogenated vegetable non-essential oils retained their essential nature, commercial identity and trade parlance as oil, so they remained classifiable under the specific excise entry for vegetable non-essential oils rather than the residual entry. The fact that the oils were processed to be non-edible did not change their character where trade evidence showed they were still known and dealt with as VNE oils. The specific tariff item therefore prevailed over the general residuary item, and classification under Tariff Item 12 was held to apply.

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Issues: Whether hardened vegetable non-essential oils manufactured for industrial use continued to fall under Tariff Item 12 of the Central Excise Tariff or were classifiable under Tariff Item 68.

Analysis: The oils in question, though hardened by chemical processing and rendered non-edible, remained oils in their essential nature. The reasoning followed the principle that a product does not cease to be what it is merely because of hydrogenation or hardening if its essential characteristics, use, and commercial identity remain unchanged. The trade evidence showed that such hardened oils continued to be known and dealt with as VNE oils. The residual entry in Tariff Item 68 could not be preferred over the more specific entry for vegetable non-essential oils where the commodity retained its oily nature and common-trade identity.

Conclusion: The hardened oils were classifiable under Tariff Item 12 and not under Tariff Item 68, in favour of the assessee.

Ratio Decidendi: A chemically hardened or hydrogenated oil does not cease to fall within the specific excise entry for vegetable non-essential oils if it retains its essential nature, commercial identity, and trade parlance as oil.

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