Chemically defined compound test upheld: liquid paraffin I.P. classified as a petroleum product, not under Chapter 29.

Liquid paraffin I.P. was held not classifiable under Chapter 29 because Chapter 29 applies only to separate chemically defined organic compounds with a definite chemical structure. The product was found to be a mixture of hydrocarbons with varying carbon chains, without a single known molecular formula or recognized structure, so it did not meet that standard. The Chemical Examiner's report supported this view, and the material relied on by the assessee did not establish a single defined compound. The product was therefore classified under Chapter 27, Heading 2710.99, as a petroleum product, and the classification adopted by the lower authorities was sustained.

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Issues: Whether liquid paraffin I.P. was classifiable under Chapter 29 as a separate chemically defined organic compound or under Chapter 27 as a petroleum product.

Analysis: Chapter Note 1(a) to Chapter 29 applies only to separate chemically defined organic compounds, whether or not containing impurities, while Chapter 27 excludes such compounds. The product in question was found to be a mixture of hydrocarbons with varying carbon chains and no single known chemical structure or molecular formula. The Tribunal applied the classification principle that a product must be chemically recognizable as a single defined compound to enter Chapter 29, and held that the absence of a definite chemical structure placed liquid paraffin I.P. outside that Chapter. The Chemical Examiner's report was consistent with this view and the material relied on by the assessee did not establish a single chemically defined compound.

Conclusion: Liquid paraffin I.P. was not classifiable under Chapter 29 and was rightly classified under Heading 2710.99 of Chapter 27, in favour of Revenue.

Final Conclusion: The classification confirmed by the lower authorities was sustained, and the appeal failed.

Ratio Decidendi: A product can be classified under Chapter 29 only if it is a separate chemically defined organic compound having a definite and recognized chemical structure, even if it contains permissible impurities.

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