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Issues: Whether imported Palm Stearin is classifiable under Chapter 15.11 or under Chapter 38.22 of the Customs Tariff Act, 1975.
Analysis: The Tribunal followed the binding decision of the Supreme Court on an identical classification dispute concerning Palm Stearin. The Supreme Court had held that the reliance placed on chemical composition, CBEC circulars, and laboratory opinions could not override the tariff schedule, and that the goods, being specifically enumerated in Chapter 38 after the amended eight-digit tariff schedule, were not classifiable under Chapter 15. The controlling principle applied was that tariff classification must follow the specific statutory entry and the settled interpretive scheme of the tariff.
Conclusion: The imported Palm Stearin is classifiable under Chapter 38.22 and not under Chapter 15.11, and the impugned order classifying it under Chapter 15.11 was liable to be set aside.
Final Conclusion: The appeal succeeded for Revenue and the earlier classification in favour of Chapter 15.11 was displaced by the correct tariff classification under Chapter 38.22.
Ratio Decidendi: Where a tariff entry specifically covers the goods in question, classification must be determined by the express tariff enumeration rather than by isolated chemical composition or administrative circulars inconsistent with the amended tariff schedule.