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Issues: (i) Whether hardened rice bran oil and inedible groundnut oil remained classifiable under Tariff Item 12; (ii) Whether Notification No. 115/75, which applied to Tariff Item 68 goods, could be claimed after such classification.
Issue (i): Whether hardened rice bran oil and inedible groundnut oil remained classifiable under Tariff Item 12.
Analysis: The classification dispute was treated as settled by the earlier binding determination that industrial oils do not lose their character merely because they undergo hardening. Once the goods retained their identity as industrial oils, classification under Tariff Item 12 followed.
Conclusion: The goods were held classifiable under Tariff Item 12.
Issue (ii): Whether Notification No. 115/75, which applied to Tariff Item 68 goods, could be claimed after such classification.
Analysis: The exemption notification was confined to goods falling under Tariff Item 68. Since the goods were held to fall under Tariff Item 12, the statutory basis for exemption was absent, and remand for a separate finding on the notification was unnecessary.
Conclusion: The benefit of Notification No. 115/75 was held to be unavailable.
Final Conclusion: The dispute was finally resolved against exemption and in favour of classification under Tariff Item 12, with no entitlement to the notified benefit.
Ratio Decidendi: Where a notification is expressly restricted to one tariff entry, goods finally held to fall under a different tariff entry cannot claim its benefit.
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