High polymers classification: bone-based gelatin and glue flakes were held classifiable under the tariff entry.

Technical gelatin and glue flakes manufactured from bones were held to fall within Item 15A(1) as "other high polymers" because the tariff term was undefined and had to be read in its technical sense. The material showed molecular weights consistent with high polymers, and the entry was not limited to synthetic or artificial products; it covered natural materials as well. Earlier rulings under the pre-1982 bone-product exemption did not control the amended tariff language applicable for the relevant period. The challenge to classification therefore failed, and the goods were correctly treated as classifiable under Item 15A(1).

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Issues: Whether Technical Gelatin and Glue Flakes manufactured from bones were classifiable under Item 15A(1) of the First Schedule to the Central Excises & Salt Act, 1944 as "other high polymers", and therefore outside the scope of exemption as bone products.

Analysis: The expression "high polymers" was not defined in the tariff and had to be understood in its technical sense. The materials relied upon showed that gelatin and glue flakes had molecular weights in the range commonly associated with high polymers. The tariff entry itself included both natural and artificial products, and the words "other high polymers" were held not to be confined to synthetic or artificial polymers. Earlier decisions concerning bone products under the pre-1982 notification did not govern the amended tariff entry in force for the relevant period. The contextual argument based on allied entries and taxing construction principles did not justify restricting the expression to artificial materials only.

Conclusion: Technical Gelatin and Glue Flakes were correctly classified under Item 15A(1) as other high polymers, and the contention that they were outside that entry failed.

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