Animal feed supplement classification prevails for poultry vitamin oral drops; form alone does not shift tariff heading.

A vitamin preparation used as oral drops for poultry was treated as an animal feed supplement under heading 2302 rather than a vitamin product under heading 2936. The relevant tariff entries and prior Larger Bench reasoning on vitamins used in connection with animal feed were applied, and the oral-drop form did not disqualify the product from classification as an animal feed supplement. The lower authority's classification was therefore set aside.

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Issues: Whether the product, being a vitamin preparation used as oral drops in poultry, was classifiable under heading 2302 as an animal feed supplement or under heading 2936 of the Central Excise Tariff Act, 1985.

Analysis: The relevant tariff entries and the Larger Bench ruling were considered. The product was treated as falling within the line of cases dealing with vitamins used in connection with animal feed, and the prior Larger Bench reasoning on similar products was found applicable. On that basis, the item could not be excluded from the animal feed supplement category merely because it was in oral-drop form.

Conclusion: The product was classifiable under heading 2302 and not under heading 2936; the finding of the lower authority was set aside.

Ratio Decidendi: A vitamin preparation used in relation to animal feed is classifiable as an animal feed supplement under heading 2302 of the Central Excise Tariff Act, 1985, and not under the residual vitamin heading merely because it is marketed in oral-drop form.

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