Classification of starch products required fresh scrutiny of the full manufacturing process and technical test evidence.

Classification of the manufactured products turned on the full manufacturing process, including steeping conditions, sulphur dioxide use, heat application and laboratory test results. The Tribunal found that the earlier adjudication had relied too heavily on the flash-drying stage and expert opinions, without properly examining the remaining process parameters or whether the chemical testing met the prescribed standard. It therefore held that plain starch versus modified starch could not be decided on the incomplete record and remanded the matter for fresh, comprehensive examination of the process and technical evidence.

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Issues: Whether the products manufactured by the assessee were correctly classifiable as plain starch or required classification as modified starch, and whether the matter needed to be remanded for fresh examination of the manufacturing process and test results.

Analysis: The dispute turned on the effect of the entire manufacturing process, including steeping conditions, use of sulphur dioxide, duration and temperature of heat application, and the chemical test results obtained on the samples. The adjudication below had relied mainly on the flash-drying stage and certain expert opinions to hold that no modification occurred, but it had not adequately examined the impact of the other process parameters or the correctness of the testing methodology. The Tribunal found that the chemical examination had not been conducted in accordance with the prescribed standard, that the impact of sulphur dioxide and the steeping conditions had not been properly considered, and that all relevant parameters of plain starch and modified starch required a fresh comparative scrutiny.

Conclusion: The matter required remand for a fresh and comprehensive examination of classification on the basis of the entire manufacturing process, relevant technical material, and proper chemical testing.

Final Conclusion: The assessee's classification dispute was not finally decided on merits, and the impugned order was set aside for reconsideration by the original adjudicating authority.

Ratio Decidendi: Where classification depends on the full manufacturing process and the available technical and laboratory evidence is incomplete or inconclusive, the adjudicating authority must examine all relevant parameters before determining whether the goods fall under the competing tariff entries.

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