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Issues: Whether Dextrose is classifiable under Chapter 29, Heading 29.40, or under Chapter 17, Heading 17.02, as chemically pure glucose.
Analysis: Heading 29.40 covers chemically pure sugars other than sucrose, lactose, maltose, glucose and fructose, and thus excludes dextrose/glucose from its scope. Chapter 17, Heading 17.02 specifically includes other sugars, including chemically pure lactose, maltose, glucose and fructose in any form. The HSN notes also support the view that dextrose is chemically pure glucose falling within Heading 17.02. The earlier authorities relied upon by the Revenue were distinguished because of subsequent amendments in the relevant chapter headings.
Conclusion: Dextrose is classifiable under Chapter 17, Heading 17.02, and not under Chapter 29, Heading 29.40; the Revenue's challenge fails.
Final Conclusion: The classification adopted by the lower appellate authority was sustained, and the Revenue appeal was rejected.
Ratio Decidendi: Where a tariff heading expressly excludes a product by name and another heading specifically includes it as a chemically pure form of that substance, classification must follow the specific inclusive entry, aided by the HSN notes and the amended tariff scheme.