Emulsifier exemption under a specific notification upheld despite tariff classification as organic surface-active agents.

Emulsifiers were treated as eligible for exemption under Notification No. 101/66-C.E. because the notification expressly covered emulsifiers, wetting out agents, softeners and similar preparations, and did not require them to be surface-active preparations in their own right. Although the tariff heading for organic surface-active agents was broad enough to include emulsifiers, that classification did not displace the specific exemption. The products had emerged from duty-paid organic surface-active agents and continued to retain their character as emulsifiers, so the Revenue's objection was rejected and the exemption was held applicable.

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Issues: Whether emulsifiers were entitled to the benefit of Notification No. 101/66-C.E. dated 17-6-1966 despite being described as organic surface-active agents.

Analysis: The notification expressly covered emulsifiers, wetting out agents, softeners and other like preparations, and did not require that such goods must themselves be surface-active preparations. The expression in the tariff heading for organic surface-active agents was held to be broader and capable of including emulsifiers, but that broader description did not take the goods outside the specific exemption granted by the notification. Since the products had already emerged from duty-paid organic surface-active agents and retained the characteristics of emulsifiers, the Revenue's objection was not accepted.

Conclusion: The exemption under the notification was held applicable to the products, and the Revenue's appeal failed.

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