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Issues: Whether Diakanol AMH was classifiable under Tariff Item 15A(i) of the Central Excise Tariff or under Tariff Item 68, and whether the trade advice relied upon by the assessee could override the specific tariff entry.
Analysis: The product was found to be an aqueous solution of polyacrylamide synthetic resin, manufactured from acrylamide through polyacrylic derivatives. Tariff Item 15A(i) covered polymerisation and co-polymerisation products including polyacrylic and polymethacrylic derivatives, and the classification scheme required technical and scientific interpretation. The Court also held that where a product squarely falls within a specific tariff entry, it cannot be relegated to the residuary item. The Chemical Examiner's observation on end-use did not displace the chemical composition-based classification, and the trade advice could not prevail over the statute.
Conclusion: Diakanol AMH was correctly classifiable under Tariff Item 15A(i) of the Central Excise Tariff and not under Tariff Item 68.
Ratio Decidendi: A product falling squarely within a specific tariff entry must be classified thereunder on its scientific and technical character, and cannot be placed in the residuary entry merely because of claimed end-use or trade advice.