Yeast cell wall classification turns on autolysis evidence, with Heading 2102 applying and customs exemption upheld.

Classification of imported yeast cell wall depended on whether the goods were autolysed yeast or merely the structural outer covering of the yeast cell. The material showed that autolysis affects the inner cellular constituents, while the cell wall itself does not undergo self-digestion; no contrary evidence established that the imported product was autolysed. It was therefore classifiable under Heading 2102 rather than Heading 2106, and exemption under Notification No. 3/2006-Cus. was available. The impugned appellate order was set aside and the original classification in favour of the importer was restored.

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Issues: (i) Whether the imported product described as Yeast Cell Wall was classifiable under Heading 2102 or under Heading 2106 as autolysed yeast, and whether exemption under Notification No. 3/2006-Cus. was available.

Analysis: The classification dispute turned on whether the goods had emerged from autolysis. The HSN notes treated autolysed yeast and yeast extracts obtained by hydrolysis as falling under Heading 2106, while yeasts in active or inactive form and other dried yeasts remained under Heading 2102. The material on record showed that yeast cell wall is the structural outer covering of the cell, that autolysis affects the inner cellular constituents, and that the cell wall itself does not undergo self-digestion or change in the process. No contrary evidence was produced by the department to establish that the imported yeast cell wall was itself autolysed. In these circumstances, the finding of the original authority that the product was not autolysed yeast and remained classifiable under Heading 2102 was accepted.

Conclusion: The product was not classifiable as autolysed yeast under Heading 2106; it was correctly classifiable under Heading 2102, and the exemption under Notification No. 3/2006-Cus. was available.

Final Conclusion: The impugned appellate order was set aside and the original classification in favour of the importer was restored, resulting in allowance of the appeal.

Ratio Decidendi: Where the evidence shows that the imported product is only the yeast cell wall and not the autolysed or hydrolysed residue of the yeast cell itself, it does not fall under the heading for autolysed yeast and remains classifiable under the general yeast heading.

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