Exemption for emulsifier or wetting out agent denied where product was fully water-soluble and not capable of forming an emulsion

The product was found to be completely soluble in water and incapable of forming an emulsion, so it did not answer the description of an emulsifier or wetting out agent. On that factual basis, exemption under Notification No. 101/66 was unavailable, and the duty levy and the Assistant Collector's action were upheld.

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Issues: Whether the product manufactured by the appellants was an emulsifier or wetting out agent entitled to exemption under Notification No. 101/66 dated 7-6-1966.

Analysis: The decisive question was the character of the product. The goods were found to be completely soluble in water and not capable of forming an emulsion. On that factual finding, the product did not answer the description of emulsifiers or wetting out agents. The claimed exemption under the notification therefore was not available.

Conclusion: The exemption claim failed and the levy of duty and the action taken by the Assistant Collector were upheld.

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