Micronutrients for plant growth qualify as fertilisers, with exemption upheld under binding classification circulars.

Micronutrients meant for plant growth were treated as fertilisers for Central Excise Tariff sub-heading 3105.00, and the exemption under Notification No. 181/86-CX was held available. The analysis applied the binding effect of departmental circulars, including the circular withdrawing the earlier contrary view, and followed the Supreme Court ratio relied upon in the document. On that basis, the contrary classification could not be sustained, and the assessee's treatment of the products as fertilisers was affirmed.

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Issues: Whether the products manufactured by the respondent, being micronutrients meant for plant growth, were classifiable as fertilisers under Central Excise Tariff sub-heading 3105.00 and entitled to exemption under Notification No. 181/86-CX dated 1-3-1986.

Analysis: The dispute turned on the classification of the products and the effect of the binding circulars governing such classification. The reasoning proceeded on the footing that micronutrients used for plant growth fall within the description of other fertilisers under sub-heading 3105.00, and that the departmental authorities are bound by the circular withdrawing the earlier contrary view. Since the issue was directly covered by the ratio of the Supreme Court decision relied upon, no different classification could be sustained.

Conclusion: The products were correctly treated as fertilisers classifiable under sub-heading 3105.00, and the exemption under Notification No. 181/86-CX was available. The appeal was therefore rejected in favour of the assessee.

Final Conclusion: The order of the lower authority granting classification and exemption was affirmed, and the Revenue's challenge failed.

Ratio Decidendi: Departmental authorities are bound by applicable circulars, and micronutrients meant for plant growth are classifiable as fertilisers for the purpose of central excise exemption.

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