Coconut oil tariff classification governed by Supreme Court ruling, with packaging determining whether it falls under edible oil or hair oil heading.

Pure coconut oil sold in small quantities as edible oil is classifiable under Heading 1513 unless the packaging satisfies Chapter Note 3 of Chapter 33, in which case it falls under Heading 3305 as hair oil. The Madras HC treated the classification question as governed by the Supreme Court's authoritative ruling and declined to decide it independently. The remaining issues raised in the show cause notice were left open for examination by the adjudicating authority on merits, and the matter was remitted for fresh adjudication on that basis.

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Issues: Whether pure coconut oil sold in small quantities as edible oil is classifiable under Heading 1513 of the First Schedule to the Central Excise Tariff Act, 1985, unless the packaging satisfies the requirements of Chapter Note 3 in Section VI-Chapter 33, in which event it falls under Heading 3305; and whether the matter should be remitted for fresh adjudication in light of the binding Supreme Court decision.

Analysis: The classification dispute was treated as settled by the Supreme Court's authoritative ruling, which held that pure coconut oil sold in small quantities as edible oil falls under Heading 1513, unless the packaging meets all the requirements of Chapter Note 3 in Section VI-Chapter 33 read with the corresponding HSN notes, in which case it is classifiable as hair oil under Heading 3305. In view of that ruling, the pending classification dispute could no longer be decided independently by the writ court. The remaining issues arising from the show cause notice were therefore left to be examined by the adjudicating authority on merits.

Conclusion: The classification issue stands governed by the Supreme Court ruling, and the matter was remitted to the respondent for fresh adjudication on that basis and on the other surviving issues.

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