Central excise classification of Prescol Glue turned on technical tariff meaning and condition at clearance, not later processing.

Prescol Glue was held classifiable under Item 15A(1) of the erstwhile Central Excise Tariff because it was a condensation product and aminoplast, and the specific entry prevailed over the residual Item 68. The Tribunal accepted that Item 15A(1) is to be read in its technical and scientific sense, but found no tariff requirement for a particular molecular weight or water solubility. Classification was determined by the product's condition at clearance, not its subsequent conversion into glue after adding extenders and hardeners. BTN, CCCN and HSN notes did not displace the tariff entry, and the reclassification under Item 68 was set aside.

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Issues: Whether the product known as Prescol Glue, manufactured from urea and formaldehyde, was classifiable under Tariff Item 15A(1) of the erstwhile Central Excise Tariff or under the residuary Tariff Item 68.

Analysis: The product was found to be a condensation product derived by chemical synthesis from urea and formaldehyde. The tariff entry for Item 15A(1) specifically covered condensation products, including aminoplasts, without requiring any particular molecular weight or completion up to a final polymerised stage. The materials on record, including the product literature and the expert report, showed that the goods were understood as synthetic resin or amino resin, and the fact that they were cleared in powder form and later converted into adhesive did not take them out of Item 15A(1). The residuary Item 68 could apply only if the product did not fall within the specific entry.

Conclusion: The product was correctly classifiable under Tariff Item 15A(1) and not under Tariff Item 68.

Final Conclusion: The Revenue's appeal succeeded, and the classification determined by the Assistant Collector was restored.

Ratio Decidendi: A condensation product specifically covered by a tariff entry cannot be shifted to the residuary entry merely because it is water-soluble, of lower molecular weight, or requires further processing before use as an adhesive.

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