Purposive interpretation of residential house exemption: unregistered purchase agreement alone does not defeat relief, but investment must be verified...
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n-Hexane was classified as a separate chemically defined compound under Chapter 29 rather than as petroleum oil or motor spirit under Chapter 27. The Court held that the Revenue bore the burden of proving Chapter 27 classification and failed to show that the product satisfied all motor spirit conditions, including suitability for use as fuel in spark ignition engines. Applying Rule 3(a) of the General Rules of Interpretation, it preferred the more specific HSN description for hexane as an acyclic saturated hydrocarbon. It further found that manufacturing impurities did not convert the product into a mixture, and relied on the DGFT circular supporting Chapter 29 treatment. The Revenue's classification claim was rejected.
n-Hexane was classified as a separate chemically defined compound under Chapter 29 rather than as petroleum oil or motor spirit under Chapter 27. The Court held that the Revenue bore the burden of proving Chapter 27 classification and failed to show that the product satisfied all motor spirit conditions, including suitability for use as fuel in spark ignition engines. Applying Rule 3(a) of the General Rules of Interpretation, it preferred the more specific HSN description for hexane as an acyclic saturated hydrocarbon. It further found that manufacturing impurities did not convert the product into a mixture, and relied on the DGFT circular supporting Chapter 29 treatment. The Revenue's classification claim was rejected.
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