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Issues: Whether liquid phenyle, being a disinfectant, was classifiable under Tariff Heading 3808.10 as insecticides or under Tariff Heading 3808.90 as others.
Analysis: The dispute turned on tariff classification under the new tariff structure. The earlier Tribunal view in Ambey Laboratories, which had treated disinfectants as falling under the residuary sub-heading because they were not specifically named in 3808.10, had since been overruled by the Supreme Court. In light of that later ruling, the exclusion-based reasoning no longer governed the classification of disinfectants under the relevant heading.
Conclusion: Liquid phenyle, being a disinfectant, fell under Tariff Heading 3808.10 and not under Tariff Heading 3808.90.
Final Conclusion: The impugned order was set aside and the appeals were allowed on the classification issue.
Ratio Decidendi: Where a later Supreme Court ruling clarifies the classification of a product under the tariff, that ruling governs and the product must be placed under the specific tariff entry applicable to its described use or character.