Edible-grade oil classification turns on carotenoid limits, denying concessional customs benefit despite compliance with acid value standards.

Imported crude palmolein qualified as edible-grade oil only if it satisfied both the acid value and the prescribed carotenoid concentration standards under the relevant tariff note and customs notification. Although the goods met the acid value requirement, the decisive failure was non-compliance with the carotenoid range, which was treated as essential for concessional classification. Following the Tribunal's earlier view in the assessee's own case, the goods were held not to meet the edible-grade standard and therefore did not qualify for the claimed customs notification benefit, with the Revenue's position prevailing.

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Issues: Whether imported crude palmolein was entitled to classification as edible-grade oil and to the concessional benefit under the relevant customs notification in view of the acid value and carotenoid concentration standards.

Analysis: The goods were found to satisfy the acid value parameter, but the decisive requirement for edible-grade classification under the relevant tariff note and notification was that the carotenoid concentration had to fall within the prescribed range. The Tribunal noted that the same issue had already been decided in the assessee's own case, where it was held that failure to meet the prescribed carotenoid limit denied the notification benefit notwithstanding compliance with the acid value standard. Following that binding decision, the Tribunal treated the imported goods as not satisfying the applicable edible-grade standard for concessional duty.

Conclusion: The imported goods were not entitled to the claimed concessional treatment, and the Revenue's appeal succeeded.

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