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Classification turned on whether imported boronated calcium nitrate fell within the watersoluble fertilizer exemption under Notification No.12/2012-Cus; the FCO specifications list unfortified calcium nitrate under watersoluble fertilizers and separately list calcium nitrate with boron under Fortified Fertilizers with distinct boron content. The Tribunal applied strict interpretation of the exemption notification and matched the product specification (higher boron content) to the Fortified Fertilizers entry, concluding the exemption for calcium nitrate did not extend to the boronated product; accordingly the revenue denial of the notification benefit was upheld and the appeals dismissed.
Classification turned on whether imported boronated calcium nitrate fell within the watersoluble fertilizer exemption under Notification No.12/2012-Cus; the FCO specifications list unfortified calcium nitrate under watersoluble fertilizers and separately list calcium nitrate with boron under Fortified Fertilizers with distinct boron content. The Tribunal applied strict interpretation of the exemption notification and matched the product specification (higher boron content) to the Fortified Fertilizers entry, concluding the exemption for calcium nitrate did not extend to the boronated product; accordingly the revenue denial of the notification benefit was upheld and the appeals dismissed.
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