TaxTMI 
TaxTMI 
2019 (10) TMI 157
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....nce to the CGST Act would also mean a reference to the same provision under the MGST Act. Further to the earlier, henceforth for the purposes of this Advance Ruling, a reference to "GST Act" would means CGST Act / MGST Act. 3. FACTS AND CONTENTION - AS PER THE APPLICANT The goods manufactured and supplied by us cover under Organic Fertilizers and the same have been certified by the INDOCERT, BIOCERT (as institute / authorities) appointed under National programme for organic Production, Department of Commerce, New Delhi. The Products mentioned in enclosed list contain Animal or Seaweed Plant excreta, Nitrogenous, Potasic Fertilizers and Micronutrients which are required for the growth and development of the plant and also used to increases overall yield and quality of plant produce. Therefore, according to us products correctly classify under HSN 3 101 or 3105. Additional submissions: PRODUCTS SUBMITTED FOR CLARRIFICATION REGARDING CLASSIFICATION IS. ORGANIC CERTIFIED PRODUCTS AS PER STANDARDS OF (NPOP) NATIONAL PROGRAMME FOR ORGANIC PRODUCTION. 1. Our product for which seeking clarification is certified Organic Products under the NATIONAL PROGRAMME FOR ORGANIC ....
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.... Weed Extract, Plant Extracts etc. [D] CLASIFICATION OF PRODUCTS 1. Fertilisers as Per FCO 1985. Definition of Fertiliser as per FCO 1985 - (h) "fertiliser" means any substance used or intended to be used as a fertiliser of the soil and/or crop and specified in Part A of Schedule I and includes a mixture of fertilizer and special mixture of fertilisers provisional fertiliser, customised fertilizer: Bio-fertilizers specified in Schedule III and Organic fertilizers specified in Schedule IV Definition of fertilizer under FCO has a functional definition and a list specific definition; Under FCO, Fertilizer should satisfy two conditions which are joined by the conjunction and' in above definitions. (i) It should be a substance used or intended to be used as a fertilizer of the soil and/or crop (basic functional definition); and (ii) It should be specified in either Part A of Schedule-I or Schedule-III or Schedule-IV. (Out of the fertilizers, which qualify the functional definition, only the fertilizers which are listed in schedule shall be subjected to controls under FCO). Therefore, the products manufactured by us are organic fertilisers by functions an....
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.... under Plant Growth Regulator. A) Further in the said Circular; category and type of PGR1 s has also been clarified/explained in detailed. Plant Growth Regulators are defined as organic compounds other than nutrients that affect the physiological processes of growth and development in plants when applied in low concentration. These are in the nature of plant hormones and classical of them are auxins, cytokinins, gibberellins (all three promoters) and abscisic acid, ethylene (both inhibitors). A list of some of the PGRs industrially produced in India is enclosed with the Circular by reply of IARI reproduce below for ready reference - S.No. Points Comments i) .......... ....................... ii) .......... ....................... iii) What are Plant Growth regulators (PGRs)' What are their functions in the plant? PGRs: Plant growth regulators defined as organic compounds other than nutrients that affect the physiological processes of growth and development in plants when applied in low concentrations. Plant growth regulators are active at low concentrations (1-10 ng / nl) in promoting, inhibiting or modifying growth and development. Th....
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....ings for retail sale or as preparations or articles (for example, sulphus-treated bands, wicks and candles, and fly-papers). HSN Explanatory Notes This heading covers : (a) Animal or vegetable fertilizers, whether or not mixed together or chemically treated; (b) Animal or vegetable products converted into fertilizers by mixing together or chemical treatment. Note: The products covered under Chapter chapter 31 are only intended for enhanced growth and not intended for adverse growth as in case of PGRs. HSN Explanatory Notes The heading further covers anti-sprouting products and plant growth regulators intended to inhibit or modify physiological processes in plants. Plant Growth Regulators are applied to alter the life processes of a plant so as to accelerate, or retard growth, enhance yield, improve quality or facilitate harvesting Note: The products covered under 38 are intended to inhibit or modify physiological changes in plants, i.e., altering or modifying the plant's structure and life processes. PGRs particularly bring hormonal changes in the plants. PGRs effect both accelerated and retarded growth. And all of them are covered in the schedule of I....
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....ous and potassium). A) We hereby declare that, list of our product submitted for seeking clarification on classification are also contain fertilising elements N-P-K (nitrogen, phosphorous and potassium) For our internal knowledge and product development we had verified (testing) N, P, K component in our products from soil. testing and bio-chemistry, laboratory 'National Horticultural Research and Development Foundation'. Taluka Niphad, Dist. Nashik and from Private Labs also. As per Lab Test Report it was confirmed that, Nitrogen and Potash available / found in the product. Copy of Lab Test Report for products Autus, Q-Prax, SJ-Eraser, Shyam Samruddhi, SJ Ninja, Stress Out, Telnar, and VK's Nemo etc. enclosed herewith for your ready reference: (Copy of Test Report enclosed Annexure - F] B) We rely on the judgement of Hon'ble CESTAT-Chandigarh in the case of Safex Chemical India Ltd. Vs. Comm. Of Central Excise Rohtak reported in 2017 (7) G.S.T.L. 234 (Tri. Chan.) = 2017 (9) TMI 140 - CESTAT CHANDIGARH, the Hon'ble CESTAT pronounced that, "Product composed of sulphates, borates, silicates of potassium, ammonium, and iron and containing auxins & cytokinins also in addi....
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.... vitality & texture. Shyam Samruddhi applicable to vegetable, horticulture trees, cereals and field crops with compatibility to urea like other fertilizers. Organic Nitrogen Source - 10.00% Organic Phosphorus Source 01.00% Organic Potash Source - 01.50% Organic Sulphar - 12.00% Humic Acid - 04.79% Glutamic Acid - 04.65% Methionine - 0.40% Phenylalanine - 0.45% Lysine - 0.32% Arginine - 0.25% Glycine - 0.30% Additives - 0.34% Organic Matter - 60.00% Organic Slow Release Soil Manur 3. SJ-NINJA NINJA SJ-Ninja is a micronutrient liquid supplying zinc and copper as a nutrient source to plants. SJ-Ninja is with pure natural properties safe to the crops & human. SJ-Ninja can be included in IPM programme. SJ-Ninja also increases plant immunity. Algal extract 10% Organic copper 0.03% Zinc. 0.9% Stabilizer 10% Aqua Q.S Micronutrient liquid 4. SJ-ERASER SJ-Eraser is a unique micronutrient liquid fomulation: SJ-Eraser gives result in 48 to 72 hours. Plant vigour and strength is developed due to use of SJ-Eraser. SJ-Eraser enhances plant immunity. SJ-Eraser can be included in IPM programme. Algal extract 10% ....
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.... Organic manure liquid 3101 00 99 Nil or 5% Other than those put-up in unit container or put-up unit container 2. SHYAM SAMRUDDHI Shyam Samruddhi is a novel combination of organic, N,P,K,S, and amino fertilizer source providing Zn, Fe, Me, Boron microelements in bioavailable form. Shyam Samruddhi acts as excellent soil conditioner improving white root development, enhancing crop quality, vitality & texture. Shyam Samruddhi is applicable to vegetable, horticulture trees, cereals and field crops with compatibility to urea like other fertilizers. Organic Nitrogen Source-10.00% Organic Phosphorus source - 01.00% Organic Potash Source -01.50% Organic Sulphur - 12.00% Humic Acid 04.79% Glutamic Acid 04.65% Methionine 0.40% Phenylalanine .45% Lysine 0.32% Arginine 0.25% Glycine 0.30% Additives 0.34% Organic Matter - 60.00% Organic Slow Release Soil Manur 3105 or 3105 90 90 5% or 18% Packages of gross weight not exceeding 10 KGS 3. SJ-NINJA SJ-Ninja is a micronutrient liquid supplying zinc and copper as a nutrient source to plants. SJ-Ninja is with pure natural properties safe to the crops & human. SJ-Ninja can....
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....s residual nitrite and nitrate, Stress Out helps the plant to sustain against adverse stresses by activating enzymes of antioxidant defence system. Stress Out enhances color, sugar content and firmness of fruits and flowers, Stress Out is a residue-free formulation. Fungal extract 10% Zinc 0.3% Antifoam agent - 05% Stabiliser -10% Solvent -Q.S. Organic manure quid 3101 00 99 Nil or 5% Other than those put-up in unit container or put-up in unit container Statement containing the applicant's interpretation of law and/or facts, as the case may be, in respect of the aforesaid question(s) (i.e. applicant's view point and submissions on issues on which the advance ruling is sought). 1. As per Customs Tariff Acts, 1975; HSN 3101 cover goods of animal or vegetable Fertilizers, whether or not mixed together or chemically treated; Fertilizers produced by the mixing or chemically treatment of animal or vegetable products. 2. The Products mentioned in enclosed list contain Animal or Seaweed Plant extract, Nitrogenous, pottassic Fertilizers & Micronutrients. It not just grows the plant, but also enhances the immunity of plant against several diseases. 3....
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.... vegetable fertilizers or organic fertilizers put up in unit containers and bearing a brand name 182D 3105 Mineral or chemical fertilizers containing two or three of the fertilizing elements nitrogen, phosphorus and potassium; other fertilizers, goods of this Chapter in tablets or similar forms or in packages of a gross weight not exceeding 10 kg, other than those which are clearly not to be used as fertilizers ;) 6. According to us as mentioned in Para 3 above our products cover under HSN 3101 and 3105 organic fertilizers respectively; and contain Animal or Seaweed Plant extract, Nitrogenous, pottassic fertilizers & Micronutrients. 5% GST rate for branded goods. The detail classification of products already submitted with the application. 7. on the basis of above information kindly advice / clarify us classification and GST rate applicable for our manufacturing goods. 04. CONTENTION - AS PER THE CONCERNED OFFICER The submission, as reproduced verbatim, could be seen thus- Fact 1:- Dealer M/s. ALLIGO AGROVET PVT LTD, has applied for advance ruling Dealer is seeking clarification on classification and GST rate applicability on the following mentioned(g....
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....Nitrogen (as N), per cent by weight, minimum 1.0 (viii) Total Phosphate (as P2O5), per cent by weight, minimum 0.8 (ix) Total Potassium (as K2O), per cent by weight, minimum 0.8 (x) Heavy metal content, (as mg/Kg), maximum Cadmium (as Cd) 5.0 Chromium (as Cr) 50.00 Nickel (as Ni) 50.00 Lead (as Pb) 100.00 3. Pressmud : (i) Moisture, per cent by weight, Maximum 15.0 (ii) Total Nitrogen (as N) per cent by weight, Minimum 1.80 (iii) Total Phosphorous(as P2O5) per cent by weight, Minimum 2.00 (iv) C:N ratio, Minimum 10:1 (v) Total Potassium (as K2O) per cent by weight, Minimum 1.40 (vi) PH 7.0-8.0 (vii) Heavy metal content, (as mg/Kg) per cent by weight, Maximum Arsenic (as As 2O3) 10.00 Cadmium (as Cd) 5.00 Chromium (as Cr) 50.00 Copper (as Cu) 300.00 Mercury (as Hg) 0.15 Nickel (as Ni) 50.00 Lead (as Pb) 100.00 Zinc (as Zn) 1000.00 PRODUCT NAME USE CONTENT DEA....
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....e activity & antiondants. Residue free, Absolutely harmless to Plant. IFOAM and Biocert certified organic immunity developer against sucking pest. Prolonged effective period when compared to technical pesticides. Multi-target sites, therefore, no chance of insect resistance. Immunity Against: - All types of Mites Algae extract 10%, organic copper 0.03%,, Zinc 0.9% stabilizer 10%, Aqua S 0.5% 31059090 3105 - 5% for 1.MINERAL OR CHEMICAL FERTILISERS CONTAINING TWO OR THREE OF THE FERTILISING ELEMENTS, NITROGEN, PHOSPHOROUS AND POTASSIUM, OTHER FERTILISERS, GOODS OF THIS CHAPTER IN TABLETS OR SIMILAR FORMS OR IN PACKAGES OF GROSS WEIGHT NOT EXCEEDING 10 KG. 2. 18% for 1.MINERAL OR CHEMICAL FERTILISERS CONTAINING TWO OR THREE OF HE FERTILISING ELEMENTS, NITROGEN, PHOSPHOROUS AND POTASSIUM, OTHER FERTILISERS, GOODS OF THIS CHAPTER IN TABLETS OR SIMILAR FORMS OR IN PACKAGES OF GROSS WEIGHT NOT EXCEEDING 10 KG. which are clearly not to be used as fertilisers 310590 - OTHER 31059090 - OTHER 1. Dealer has classified this product on his website under head IMMUNITY AGAINST SUCKING PEST 2. On the basis of definition of organic fertilizer as per order no. 11-3/83-STU, Go....
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....m-free to crop, Not harmful for honeybees and other beneficial insects. Broad-Spectrum IFOAM certified,MPKV tested and patented organic immunity developer against fungus, Initiates intracellular free radical formation resulting in DNA and mRNA damage. Shows killer effect on surface as well as intracellular fungi. Residue-free, absolutely harm-free to crop. Equally effective against soil borne fungi and oomycete fungal infection. Dosage:-2.0 ml/liter with Aqua-s spreader (0.5 ml / liter) Acre:- 0.5-0.7 L / acre Algae extract 10% Organic copper 0.6%, stabilizer 10%, Aqua S 0.5% 31059090 3105 - 5% for 1.MINERAL OR CHEMICAL FERTILISERS CONTAINING TWO OR THREE OF HE FERTILISING ELEMENTS, NITROGEN, PHOSPHOROUS AND POTASSIUM, OTHER FERTILISERS, GOODS OF THIS CHAPTER IN TABLETS OR SIMILAR FORMS OR IN PACKAGES OF GROSS WEIGHT NOT EXCEEDING 10 KG. 2. 18% for 1.MINERAL OR CHEMICAL FERTILISERS CONTAINING TWO OR THREE OF HE FERTILISING ELEMENTS, NITROGEN, PHOSPHOROUS AND POTASSIUM, OTHER FERTILISERS, GOODS OF THIS CHAPTER IN TABLETS OR SIMILAR FORMS OR IN PACKAGES OF GROSS WEIGHT NOT EXCEEDING 10 KG which are clearly not to be used as fertilisers 310590 - OTHER 31059090 ....
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....lement 4. Packing - 50 lit drum SHYAM SAMRUDDHI Organic Nitrogen source 10% Organic phosphorous source 1%, Organic potash source 1.50%, Organic sulphur 12%, Humic acid 4.79%, Glutamic acid 4.65%, Methionine 0.4%, Phenylanine 0.4%, Lysine 0.32 %, Act as a excellent soil conditioner 31059090 3105 - 5% for 1.MINERAL OR CHEMICAL FERTILISERS CONTAINING TWO OR THREE OF HE FERTILISING ELEMENTS, NITROGEN, PHOSPHOROUS AND POTASSIUM, OTHER FERTILISERS, GOODS OF THIS CHAPTER IN TABLETS OR SIMILAR FORMS OR IN PACKAGES OF GROSS WEIGHT NOT EXCEEDING 10 KG. 2. 18% for 1.MINERAL OR CHEMICAL FERTILISERS CONTAINING TWO OR THREE OF HE FERTILISING ELEMENTS, NITROGEN, PHOSPHOROUS AND POTASSIUM, OTHER FERTILISERS, GOODS OF THIS CHAPTER IN TABLETS OR SIMILAR FORMS OR IN PACKAGES OF GROSS WEIGHT NOT EXCEEDING 10 KG.which are clearly not to be used as fertilisers USE - Improving white root development, enhancing crop quality, vitality and texture. Packing - 50 kg. VKS NEMO Immunity Towards Root knot nematode, Rhabditida, Dorylaimida, Triplonchida, etc. Quick result around 48 to 72 hours due to induced oxidative stress. Totally biodegradable Slow elease for prolonged a....
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....NITROGEN, PHOSPHOROUS AND POTASSIUM, OTHER FERTILISERS, GOODS OF THIS CHAPTER IN TABLETS OR SIMILAR FORMS OR IN PACKAGES OF GROSS WEIGHT NOT EXCEEDING 10 KG. which are clearly not to be used as fertilisers 1 Dealer has classified this product on his website under head IMMUNITY AGAINST CHEWING PEST 2. On the basis of definition of organic fertilizer as per order no. 11-3/83- STU, Govt of India ministry agriculture and rural development (Department of Agriculture and co-operation) New Delhi, date. 25^th Sep 1985 The fertilizer (Control) Order 1985, this is not a city compost, vermin compost or press mud. Dealer has availed exemption under this entry as per Notification No. 12/2012-Central Excise dated 17.03.2012 under entry no 128, chapter 31 where All goods, other than those which are clearly not to be used as fertilisers, rate. Main use - Immunity developer Packing - 50 Lit Also in this regard, when asked to dealer about how to identify the product use for plant, he stated, specifications of the plant disease, or requirement should be specify to give proper product to the plant. Additional submissions on 03.08.2019 Findings: Autus- 1. This product ....
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....s that the product seems to be an organic pesticide and may fit in that HSN category 3808 (18%) rather than 3105. SJ-eraser- 1. This product is certified as organic product by an accredited certifying agency. It is not mentioned anywhere that it is an organic fertilizer. 2. Salient features mentioned for this product shows that this product develop immunity against several pest. Further it also claims to have protection against all larval stages and pesticidal (larvicide) results can be achieved within 48 to 72 hours. Graphics also indicates potential pesticidal effect especially mode of action and effect against particular insects in larval stages. This shows product may feet in the HSN category 3808 (18%). 3. Flow chart of manufacturing process does not show any fertilizer claim. 4. This shows that the product seems to be organic pesticide and may fit in that HSN category 3808 (18%) rather than 3105. O-prax- 1. This product is certified as organic product by an accredited certifying agency. It is not mentioned anywhere that it is a organic fertilizer. 2. Salient features mentioned for this product shows that this product....
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.... Stress-out- 1. This product is certified as organic product by an accredited certifying agency. It is not mentioned anywhere that it is an organic fertilizer. 2. Salient features mentioned for this product shows that it helps in plant growth promotion and adding value to increase yield and quality produce. This doesn't seems to have plant growth regulator effect such as synthetic (inorganic PGR) hormones. This product may not feet in the HSN category 3808. 3. Flow chart of manufacturing process also shows that element like silicates are used as input. 4. It is not clear for this product how it can fit into manure or fertilizer category. 5. This shows that the product seems to be organic plant growth stimulant or may be organic ant growth regulator and may fit in HSN category 38089340 (PLANT GROWTH REGULATORS). Overall comment: The products Autus and Shyam samruddhi seems to be plant growth promoters and may in 3101 or 3105 and it does not have any pesticidal claim nor any synthetic plant growth regulator (PGR) is used in the manufacturing process. However, the product Stress-out does not seems to be clearly comes in the category o....
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....cation are classifiable under HSN 3101 or 3105. We find that, applicant have different lines of arguments. The first line of argument is that, the products are organic fertilizer and exempt from payment of tax. The second line of argument to buttress first line of argument is that, the products do not fall under the category of Pesticides. Applicant submit that, their products are not of the category of pesticides as they are having fertilizing element that promote health plant growth and plant immunity. The product manufactured by the applicant have organic extract of plant an animal origin i.e. products have marine - Seaweed extract, plant extract. Applicant further submits that, the product manufactured by them are organic fertilizer by functions and also having fertilizing element. Further, they are not to be governed under Fertilizer Control Order, 1985 as well as Insecticide Act, 1968. Further line of argument of the applicant is that, the products are not covered under the expression plant growth regulator (PGR). Before determining the correct classification of the products in question, it is necessary to analyze characteristics of fertilizer, organic fertilizer, plant gr....
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....etimes appear to be active in regulating plant growth, the brassinosteroids and polyamines. Auxins stimulate cell elongation and influence a host of other developmental responses, such as root initiation, vascular differentiation; Cytokinins are able to stimulate cell division and induce shoot bud formation. They usually act as antagonists to auxins. Cytoknins often inhibit embryogenesis and root induction; Gibberellins: The main effect of gibberellins in plants is to cause stem elongation and flowering. They are also prominently involved in mobilization of endosperm reserves during early embryo growth and seed germination; Abscisic acid (ABA) in plants is a terpenoid involved primarily in regulating seed germination, inducing storage protein synthesis and modulating water stress. In plant tissue culture, it is used to help somatic particularly during maturation and germination; Ethylene is a simple gaseous hydrocarbon with the chemical structure H2C=CH2. Ethylene is apparently not required for normal vegetative growth. However, it can have a significant impact on development of root and shoots. Usually, ethylene is not used in plant tissue culture. Difference between Fertilizer....
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....t to alter its life processes or its structure to improve quality, increase yields etc. Thus, Autus satisfy all the ingredients of plant growth regulators (PGR) and therefore classifiable under Tariff Heading 3808 with applicable GST @18%. Product : SHYAM SAMRUDDHI : Applicant submits that, the product is combination of organic N,P,K,S and Amino Fertilizers. The said product provides micro elements like Zn, Fe, Mn, Boron in bioavailable form. The product also acts as soil conditioner and maintain soil moisture for longer period. We find that, the plant nutrient such as N, P, K are derived from organic source. The product is also certified by the Accredited Certified Agency as Organic Products. The product does not contain any other growth regulator as such the product is Organic Fertilizer classifiable under HSN-3 IOS and liable to GST as per sr. No. 182D of Schedule-I of Notification No. 1/2017-CT (Rate) dated 28.06.2017. Product: SJ-NINJA : Applicant submit that, the product is algae extract containing organic copper zinc etc. Applicant further submit that, the product is IFOAM and Biocert certified organic immunity developer against insects. However, from the peru....
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....roduct is advertised as broad spectrum organic fungicide effective against plant fungi and soil born fungi. The product is effective against Downey mildew, Pythium fusarium, Rust, fire blight, powdery mildew etc. From the salient features of the product as mentioned above we have no doubt to consider the product as Organic Fungicide falling under HSN-3808 liable to GST @18%. Product: TELNAR : Applicant submit that, Telnar is a micro fertilizer liquid intended to achieve better yield. We find that, the product is certified as Organic product by the competent agency. However, there is no mention that, the product is an Organic Fertilizer. However, we find from the mode of action that the product bind to peptidoglycan on the cell wall altering osmatic pressure resulting sudden death of target bacteria or spore. Further the product causes damage to DNA and mRNA. The product show clear effect on gram positive as well as gram negative pathogenic bacteria. The product is used against target bacteria such as Xanthomonos axomopodis punicae (oily spot blight), X. botrytis, X. campestris. The product is advertised by the appellant as broad spectrum organic bactericide. In this view of t....
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....td. vis. Union of India, 1992 (57 ELT 401 BOM) = 1991 (7) TMI 95 - HIGH COURT OF JUDICATURE AT BOMBAY. The relevant para of the said judgment is produced herein below. "3. The first submission urged by Shri Hidayatullah is that the Assistant Collector was in error in rejecting the claim of the Company by relying upon the personal observations made during the visit to the factory. It was urged that the personal observations of the Officer cannot determine the classification of the goods and in support of the submission reference was made to the decision of the Single Judge reported in 1981 (8) E.L.T. 432 (Bom.) = 1981 (2) TMI 83 - HIGH COURT OF BOMBAY Advani Oerlikon Ltd. and Another v. Union of India and Others. The submission is not correct. It is undoubtedly true that the Officer cannot base his conclusion solely upon the observations made during visit to the factory as normally, the Officer adjudicating the case is not necessarily expert in the process of manufacture. In the present case, the Assistant Collector has passed order of adjudication not merely on the strength of observations made during the visit but on several other circumstances. Indeed, we appreciat....