TaxTMI 
TaxTMI 
1999 (3) TMI 345
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.... [Order per : Jyoti Balasundaram, Member (J)]. - The dispute in the above appeal relates to classification of following Cationic Surface Softeners for softening of textiles and treating of leather : 1. Sapamin OC 2. Sapamin OC liquid 3. Sapamin P 4. Irgamin 1281 2. The appellants filed classification list No. 105/91 classifying the above products under CET sub-head....
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....e appellants filed another classification list bearing No. 112/91-92 effective from 28-8-1991 under Heading 38.09 which was approved by the Assistant Commissioner on 18-9-1991. 3. The Department filed an appeal under Section 35E(2) against the approval of classification list No. 105/90-91 in respect of three products namely Sapamin OC, Sapamin OC liquid and Sapamin P and also filed an appeal....
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....d from a non-surface active reaction product aided by a small amount of surface active agent which is externally added, and since the softener is thus not based upon an OSAA, it falls outside the purview of Chapter 34. He has noted that the requirement of reduction of surface tension of water to 44 d/cm or less by a OS solution in water is only for surface active agents (Note 3(b) to Chapter 34) a....
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.... report is to be given preference over the opinion of Prof. Subramaniam whose opinion is a general one, and is not based on actual testing of the samples of the products. The appellants had also furnished the opinion of Dr. V.A. Shenai of Bombay University who confirmed that the products in dispute were finishing agents or softners used in textile industry for softening of textile fabrics and that....