Mangala Borosan and G1 Not Classified as Fertilizers Due to Lack of Essential Elements; Upheld by AAAR Decision.

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....Mangala Borosan and Mangala G1 are not classifiable under Chapter Heading 3105 as Fertilisers as they lack essential fertilizing elements like Nitrogen, Phosphorus, or Potassium as stipulated by Chapter Notes. Classification is determined by product description, inclusion/exclusion in Section/Chapter Notes, and General Rules of Interpretation, not claimed usage or results. Appellant's contention of Nitrogen emanation during usage is untenable as products are assessed based on form and contents at presentation/supply. Definition of "Fertiliser" under relevant law requires essential plant nutrients like Nitrogen, Phosphorous, and Potassium, irrespective of State Government's notification of micronutrients. AAAR upheld classification outside Chapter 31.....