Dispute Over "Commingled Crude Oil" Classification: Burden of Proof on Department, Not Appellants, Under Central Excise Rules.

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....Classification of goods - appellants procured “Commingled Crude oil” and Dehydration process was undertaken - merely alleging that the burden was on the appellants is not acceptable - the onus of proving the classification is on the Department which has not clearly discharged the burden of doing so.....