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    <title>2025 (1) TMI 156 - CESTAT AHMEDABAD</title>
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    <description>A specific tariff entry must be applied strictly to its own description, and the Revenue must prove that imported health supplements fall within the higher-rated goods listed in Schedule IV. In the absence of test reports or other evidence showing that the goods were protein concentrates, textured protein substances, or food flavouring material, they remained classifiable under the residuary entry in Schedule III and attracted IGST at 18%, not 28%. The extended limitation period could not be invoked where the imports and classification were disclosed in the bills of entry, no suppression was shown, and the matter was revenue neutral. The differential IGST demand was therefore barred by limitation.</description>
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      <link>https://www.taxtmi.com/caselaws?id=764094</link>
      <description>A specific tariff entry must be applied strictly to its own description, and the Revenue must prove that imported health supplements fall within the higher-rated goods listed in Schedule IV. In the absence of test reports or other evidence showing that the goods were protein concentrates, textured protein substances, or food flavouring material, they remained classifiable under the residuary entry in Schedule III and attracted IGST at 18%, not 28%. The extended limitation period could not be invoked where the imports and classification were disclosed in the bills of entry, no suppression was shown, and the matter was revenue neutral. The differential IGST demand was therefore barred by limitation.</description>
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