Amended tariff classification for aqueous resin solutions upheld under Item 15A; earlier wording no longer controlled.

The amended Central Excise Tariff Item 15A covered materials in liquid or pasty form, including emulsions, dispersions and solutions, and this wider wording supported classification of Morarfloc under Item 15A rather than Item 68. On the evidence, the product was treated as an aqueous solution with substantial water content, not a fully manufactured resin outside the amended entry. The earlier classification history was relevant only to the pre-amendment period, and reliance on the chemist's report was found unobjectionable. The assessee's challenge to the demand and refusal of refund therefore failed.

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Issues: Whether the product Morarfloc was classifiable under Tariff Item 15A of the Central Excise Tariff after the 1982 amendment, or remained classifiable under Tariff Item 68.

Analysis: The amended tariff entry expressly brought within Tariff Item 15A materials in liquid or pasty form, including emulsions, dispersions and solutions. The product was found on the evidence to be an aqueous solution with substantial water content and not a fully manufactured resin outside the scope of the amended entry. The earlier classification dispute had been decided on the unamended tariff wording, but the later amended description materially enlarged the entry and supported classification under Tariff Item 15A. The Court also found no infirmity in reliance on the chemist's report or the earlier classification history for the pre-amendment period.

Conclusion: The product was held classifiable under Tariff Item 15A, and the assessee's challenge to the demand and rejection of refund failed.

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