Chemical classification of enzyme: wide entry covered enzyme, so the residuary category could not apply.

The expression "chemicals of all kinds" was held wide enough to include enzyme, applying dictionary meanings, expert material and the common parlance test. The Revenue failed to show that enzyme, even if regarded as a protein, was excluded from the specific chemical entry, so the residuary category could not be used. Enzyme was therefore classified under the chemical entry in Notification No. 1084 dated 25.02.2003 and treated as taxable at 4%.

---

---

Issues: Whether enzyme is classifiable as a chemical under Notification No. 1084 dated 25.02.2003 and taxable at 4%, or is an unclassified item taxable at 10%.

Analysis: The expression "chemicals of all kinds" was held to be wide enough to include enzyme. The State failed to produce material to show that enzyme, even if viewed as a protein, would fall outside the chemical entry. The court relied on dictionary meanings, expert material, and the common parlance test to hold that enzyme is understood as a catalytic chemical substance and not as a separate residuary item. The residuary entry could not be invoked when the goods were covered by the specific entry.

Conclusion: Enzyme falls under the chemical entry in Notification No. 1084 dated 25.02.2003 and is taxable at 4%.

Ratio Decidendi: Where a goods entry is expressed in wide and inclusive terms, classification must be determined by common parlance and the burden lies on the Revenue to show that the goods are excluded from the specific entry before resorting to the residuary category.

---