TaxTMI 
TaxTMI 
TaxTMI 
2026 (1) TMI 24
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....med that Yara Fertilisers India Private Limited is a subsidiary of Yara International ASA, Norway, which is a global leader in agricultural products and environment protection agents including nitrates, calcium nitrate, micronutrients, and Nitrogen, Phosphorus, and Potassium (NPK) Fertilizer. Further, the Applicant is inter alia engaged in import and distribution of various types of and grades of fertilizer (including micronutrients fertilizers), in India. The Applicant has been in this business since the year 2011. 3. Applicant's submission in respect of the subject goods: 3.1. Yara Vita Bud Builder is the brand name of the product "Magnesium Hydroxide and Zinc Phosphate Micronutrient Fertilizer". 3.2. Yara Vita Bud Builder is a fertilizer with macro and micronutrients primarily comprising of Phosphorous, Magnesium, Zinc and Boron. The physical appearance of the fertilizer is a 'beige powder' and has partial solubility in water. YaraVita Bud Builder is specifically meant for foliar application and improves flowering and aids in nutritional management. Further, YaraVita Bud Builder is safe for all crops and can be used in tandem with. 3.3. The Applicant i....
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....e tetrahydrate [2.5- < 15]. Furthermore, Magnesium, Zinc and Phosphorous are present in a recognizable quantity in the entire composition of Yara Vita Bud Builder. 5. Compliance with the Fertilizer (Inorganic, Organic or Mixed) (Control) Order, 1985: 5.1 The Applicant has been issued with valid license for import and trade of fertilizers under Fertilizer (Inorganic, Organic or Mixed) (Control) Order, 1985 ('FCO'). 5.2 The Government of Maharashtra, Director of Agriculture (I & QC) Maharashtra State has issued the Applicant with License No. LCFWD2022120892 dated 29.07.24. 5.3 Statement-I of the FCO License contains 'Details of Fertiliser Grades / Sources' which the Applicant is licensed to import and sell in Maharashtra SI. No. 3 of the License specifically permits the Applicant to import and sell 'Magnesium Hydroxide and Zinc Phosphate Micronutrient Fertilizer' i.e., YaraVita Bud Builder, supplied by Yara UK Limited, Pocklington (referred to as 'Yara Pockl' in the license). 5.4 The imported goods are always supplied to the dealers who have been issued with fertilizer license under FCO. The Appellants always provide end-use declarati....
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....atory Notes aid in the interpretation of the Headings of the Tariff and may be used as a safe guide for the same. 6.4 The Applicant submits that the imported Yara Vita Bud Builder merits classification under Heading 31.05 and specifically under Tariff Item 3105 90 90 as 'Other Fertilizers'. Relevant portion of the Heading 31.05 is reproduced below: Tariff Item Description of goods 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 10KG 31051000 - Goods of this chapter in tablets or similar forms or in packages of a gross weight not exceeding 10kg 31052000 - Mineral or chemical fertilizers containing the three fertilizing elements, nitrogen, phosphorus, and potassium 31053000 - Diammonium hydrogen ortho phosphate (diammonium phosphate) 31054000 - Ammonium dihydrogen ortho phosphate (monoammonium phosphate) and mixtures thereof with diammonium hydrogen orthophosphate (diammonium phosphate) - Other mineral or chemical fertilizers contai....
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....ry Nutrients (Nitrogen, Phosphorous and Potassium), Secondary Nutrients (Calcium, Magnesium and Sulphur) and Micro Nutrients (Zinc, Manganese, Copper, Iron, Boron and Molybdenum); (ii) "Beneficial clement" means any clement as notified by the Central Government from time to time.'; (iii) in Schedule I, for part A and the entries relating thereto, the following entries shall be substituted, namely: - ... " 6.9.2 The Association of American Plant Food Control Officials (AAPFCO) defines 'Fertilizer' as under: - "Any substance containing one or more recognized plant nutrient(s) which is used for its plant * nutrient content, and which is designed for use or claimed to have value in promoting plant growth, except unmanipulated animal and vegetable manures, marl, lime, limestone, wood ashes and other products exempted by regulation". 6.9.2 Further, the definition of 'Fertilizer' as per Farm Chemical Handbook '98 - Electronic Pesticide Dictionary reads as follows: "Any natural or manufactured material added to the soil in order to supply one or more plant nutrients. The term is generally applied to manufactured material oth....
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....inc. 6.15 The FCO defines a Fertiliser as "essential substance, either in straight or mixed form and derived from either inorganic, organic or mixed sources, that is used or intended to be used to provide essential plant nutrients .... " Furthermore, as per the explanation contained within the definition of fertilizer, "essential plant nutrients" include Primary Nutrients (Nitrogen, Phosphorous and Potassium), Secondary Nutrients (Calcium, Magnesium and Sulphur) and Micronutrients (Zinc, Manganese, Copper, Iron, Boron and Molybdenum). Therefore, a mixture of Primary and Secondary as well as Micronutrients are Fertilizers. 6.16 Further, the explanation to 'Primary Nutrients' under the FCO is identical to what are considered as the Fertilizing elements under the Note 6 to Chapter 31. In other words, both legal regimes (FCO and Customs Tariff) consider a mixture containing either of the elements "N,P,K" as a Fertilizer. Therefore, once the imported goods meet the definition of Fertilizer under the FCO, they ought to be considered as a Fertilizer under the Customs Tariff. 6.17 'YaraVita Bud Builder' is the brand name for Magnesium Hydroxide and Zinc Phosphate M....
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....alogue, and MSDS of Yara Vita BudBuilder have already been enclosed as Annexure-5 & 6, respectively. 6.22 Further, YaraVita BudBuilder conforms to FCO standard specified for 'Magnesium Hydroxide and Zinc Phosphate Micronutrient Fertilizer' is undisputed. To this extent the Government of Maharashtra, Director of Agriculture (I & QC) Maharashtra State has issued the Applicant with FCO License No. LCFWD2022120892 dated 29.07.24 which covers Magnesium Hydroxide and Zinc Phosphate' as a Micronutrient Fertilizer supplied by Yara Pockl (Yara UK Limited, Pocklington) 6.23 Therefore, condition (a) to Note 6 to Chapter 31 as stated in paragraph above is fulfilled as the imported goods are a fertilizer, recognised as a fertilizer under the FCO and are used as a fertilizer. YaraVita BudBuilder contains Phosphorous (P) (one of fertilizing elements) as an essential constituent. 6.24 The Applicant submits that one of the essential constituents of Yara Vita BudBuilder is Phosphorus and therefore, the goods meet condition (b) contained in Note 6 to Chapter 31. As detailed in the forgoing paragraphs, imported goods are a mixture of Phosphorous, Magnesium, Boron and Zinc....
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....hich are admittedly for promoting only growth and health of plant cannot logically find a place in this heading. 8.6 It is interesting to note that CBEC found it necessary to issue yet one more circular No.1022/10/2016-CX, dated 06.04.2016, on the very issue of classification of micronutrients, plant growth regulators etc. In the first para itself, the circular acknowledges that the issue of classification of these items remain a disputed area in Central Excise. On the basis of opinion obtained from Indian Agricultural Research Institute (IARI), Central Excise Tariff explanatory notes, nature, usage etc., the CBEC has clarified, inter-alia, that micronutrients are essential nutrients and required in small quantities for the normal growth and development of plants containing elements like iron, Manganese, Zinc, Copper, Boron, Molybdenum, Nickel etc. Board has also acknowledged that these micronutrients are sold in the market as micronutrient fertiliser. It has, however, clarified that for classification under chapter 31, at least one of the elements viz; Nitrogen, phosphorous or potassium should be an essential constituent of the fertiliser. Board has also clearly different....
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.... phosphate" with purity of 99.6%. The dispute was to ascertain whether the imported goods are "fertilizers" within the meaning of Chapter 31 of the First Schedule of the Customs Tariff Act, 1975 or are covered by Chapter 28, in particular Tariff Item 28 35 2400 which covers "phosphate of potassium". The Hon'ble CESTAT held that Note 6 of chapter in relation to the residuary category restricts classification under "other fertilizers" in 31.05 to goods to be used as "fertilizers" and containing one of the fertilizing elements. Relevant portion of the aforesaid decision reads as under: "6. Having heard both the sides, we find that the dispute lies within the narrow compass of ascertaining whether the imported goods are "fertilizers" within the meaning of Chapter 31 of the First Schedule of the Customs Tariff Act, 1975. The two rival entries are "phosphate of potassium" and "fertilizers" containing two fertilizing elements phosphorous and potassium. Note 1 of Chapter 28 indicates that the heading of that chapter would only apply to items listed in the said note among which are separate chemically defined compound. With reference to HSN Explanatory Notes under Heading 31.05....
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.... goods are not fertilizer. For the above reasons, we find that the classification of the imported goods should fall under Chapter 31 and not Chapter 28. The inclusions of the imported items in the Fertilizer (Control) Order, 1985, as amended in 1995, cannot but reinforce the opinion that these are indeed fertilizers as decided by the competent department of the Government of India. ... [Emphasis Supplied] 7.3 A similar view has also been taken in the following decisions: a. CCEx. Vs. Rallis India - 2005 (186) ELT 382 (Tri .- Chennai); b. Assam Company Ltd Vs. CC - 2001 (133) ELT 110 (Tri .- Kolkata) [affirmed by the Hon'ble Supreme Court in 2002 (146) ELT A218]; and c. Transpek Industry Ltd Vs. CCEx. - 2008 (230) ELT 351 (Tri .- Ahmd.) d. CC (Exports) Vs. SLV Fertichem - 2018-VIL-71-CESTAT-CHE-CU 7.4 In CCE, Mumbai Vs. Aries Agrovet Industries - 2018 (6) TMI 1070, the micronutrients owing to the presence of Nitrogen were classified under the Heading 31.05. The Hon'ble CESTAT has held that the product which contains recognizable percentage of nitrogen comes under the ambit of micronutrient fertilizers and are classifiable as '....
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.... (a) used solely as a fertilizer and; (b) one of its essential constituents is the fertilizing element 'Phosphorus' which is present in a recognizable quantity of 6.9%. Therefore, YaraVita Bud Builder containing a recognizable percentage of Phosphorous i.e., 6.9%, which is a fertilizing element and an essential constituent is classifiable under Tariff Item 3105 90 90. Port of Import and reply from jurisdictional Commissionerate: 9. The applicant in their CAAR-1 indicated that they intend to import the subject goods from O/o Pr. Commissioner of Customs, JNCH, Uran. The application was forwarded to the jurisdiction for their comments on 23.05.2025, 17.06.2025, 08.08.2025 and 15.09.2025, however no response was received from the jurisdictional authority. Details of Personal Hearing: 10. A personal hearing was held on 09.07.2025 in this matter. Ms. Madhura Khandekar and Shri Sidharth Sen both Authorized representatives appeared for PH on behalf of the applicant. They reiterated the submission filed with the application and submitted that subject goods i.e "Yara Vita Bud Builder brand name for 'Magnesium Hydroxide and Zinc Phosphate Micronutrien....
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....agnesium |Magnesium Oxide] 24% 40% 7. Boron 3% 8. Zinc 10% 13.2 Further, the Certificate of Conformity (hereinafter referred to as "COC") issued in compliance with the ECC Regulation (EC) No. 2019/1009 also states that YaraVita Bud Builder is inter alia comprised of the following nutrients/ micronutrients: SI. No. Nature of element Name Specification % w/w 4. Primary Nutrients Phosphorous 2.5 5. Secondary Nutrients Magnesium 24.0 6. Micronutrients Zinc 10.0 Further, I find as per material Safety Data Sheet (hereinafter referred to as "MSDS") of Yara Vita Bud Builder under Section 3: 'Composition/Information on ingredients', states that it is a 'Mixture' of (a) trizinc bis(orthophosphate) [20- < 25] and (b) disodium octaborate tetrahydrate |2.5- < 15]. Furthermore, Magnesium and Zinc are present in the quantity predominantly 10% or more than that (Magnesium 24%, Magnesium Oxide 40% and Zinc 10%). Whereas, Boron and Phosphorous are present as per COC 3% and 2.5% and as per TDS 3% and 6.9% respectively, which are comparatively in lesser quantity in the subject goods. 13.3....
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....er, the applicant themselves claimed the product as "Micronutrient Fertilizer" listed under SI. No. 24, Sub-Heading 1(g) of Part A of the Schedule I of the FCO, 1985. 15. Now, before deciding the issue of classification of the subject goods, let me deliberate on the legal framework prescribed in Customs Tariff Act, 1975. Chapter/ Section notes along with HSN explanatory notes, circular No. 1022/10/2016-CX dated 6-4-2016. As per Rule 1. of GRI, the titles of Sections, Chapters and sub-Chapters are provided for case of reference only; for legal purposes, classification shall be determined according to the terms of the headings and any relative Section or Chapter Notes. 16. Fertilizer is not defined in the Customs tariff or Customs Act. Fertilizer (Inorganic, organic and Mixed) (Control) Order, 1985) (hereinafter referred to as FCO, 1985) as amended, defines the Fertilizer as per follows: h. "fertiliser" means any essential substance, either in straight or mixed form and derived from either inorganic, organic or mixed sources, that is used or intended to be used to provide essential plant nutrients or beneficial elements or both for the soil or for the crops or makes es....
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....al constituent of the fertilizer as per chapter note 6 of chapter 31. 2.2 There is no specific heading in the tariff for classification of micronutrients. However, where the micronutrient is a separate chemically defined compound, it will be classifiable under the heading for that chemically defined compound under chapter 28 or chapter 29. For example, some of the sulphates of micronutrients are specifically covered under CETH 2833. 2.3. Vide Notification no. 12/2016 - C.E dated 1.3.2016, Notification no. 12/2012 - CE dated 17.3.2012 has been amended and a new serial no 109A has been inserted to exempt duty of excise in excess of 6%, payable on micronutrients classifiable under chapter 28, 29 or 38 and covered under serial number 1(f) of Schedule 1, Part (A) of the Fertilizer Control Order, 1985 and manufactured by the manufacturers registered under the Fertilizer Control Order, 1985. 4.1 Fertilizers are classified under chapter 31 of the Central Excise Tariff and for this purpose they may interalia be minerals or chemical fertilizers - nitrogenous (CETH 3102), phosphatic (CETH 3103), potassic (CETH 3104) or fertilizers consisting of two or three of the f....
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....r. On careful reading of the said circular (which is issued after taking opinion of IARI). It is apparent that: i) In the trade parlance sale of micronutrients as 'micronutrient fertilizers' would not lead to classification thereof under chapter 31 as fertilizers. ii) where the essential character of the product is that of mixture of micronutrients multi- micronutrients having predominately trace elements, it shall be classified under CETH 3824 as chemical products not elsewhere specified or included. iii) Nitrogen, Phosphorus and Potassium are macronutrients/primary fertilizer element and are required in the higher quantity by the plants as against the micronutrients/secondary nutriments. Thus, it is predominance of Nitrogen or potassium or phosphorous that determines the essential character of the product. iv) Notifications issued under Fertilizer Control Order are not relevant for deciding classification. The General HSN Explanatory Note to the Chapter 31 which we will see in next paragraphs, in clear terms provide that Micronutrients preparation containing small amount of Nitrogen, Potassium and Phosphorous are excluded from the fe....
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....nt preparation which is used as a fertilizer. The subject do contain small amount of Phosphorus as Phosphorus pentoxide which is just 2.5% by weight as per COC (Certificate of Conformity) issued by EU and 6.9% as per TDS (Technical Data Sheet). However, based on the composition the subject goods I find that phosphorus is not the essential constituent which gives essential character to the subject goods i.e YaraVita Bud Builder-'Magnesium Hydroxide and Zinc Phosphate Micronutrient'. The subject goods are actually a micronutrient fertilizer which are covered under SI. No. 24, Sub-Heading 1 (g) - Micronutrients category of Schedule I Part A of FCO, 1985 and the same also confirms to the parameters mentioned therein. It is the mixture/preparation of micronutrients containing secondary nutrient Magnesium (24%) and Micronutrients Zinc (10%) and Boron (3%) and a meagre quantity of primary nutrient Phosphorous (2.5%). Micronutrients/mixture of Micronutrients viz Mg, Zn, B are the essential constituents providing essential character to the subject goods making it fall under the category of Micronutrient fertilizer. Further, Phosphorous is not the essential element deciding the actua....
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....ar provisions of the law it is apparent that: Section 2(h) of FCO defines fertilizers as any essential substance, either in straight or mixed form and derived from either inorganic, organic or mixed sources, that is used or intended to be used to provide essential plant nutrition or beneficial element or both for the soil or for the crop or makes essential plant nutrients available to the plants either directly or by biological process or by both in the soil or plant as notified from time to time by Central Government and specified in the schedules appended to this order or as may be notified by the State Governments. On going through the explanation given in the FCO 1985 to para (h)- For the purpose of fertilizer: - (i) "the essential plant nutrients include primary nutrients (Nitrogen, Phosphorous and Potassium), Secondary Nutrients (Calcium, Magnesium and Sulphur) and Micro nutrients (Zinc, Manganese, Copper, Iron, Boron and Molybdenum) (ii) Notified beneficial elements. The "essential plant nutrients" has three categories: - (a) Primary Nutrients- Nitrogen, Phosphorous and Potassium (b) Secondary Nutrients- Calcium, Magnesium and Sul....
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....f the element is sufficient to determine the product as 'Micronutrient Fertilizer. Here, I find it correct that there is no specific percentage is provided in the Customs Tariff Act and HSN Explanatory Notes, but it could be seen that the language employed in the Heading 3105, Note 6 of the Chapter 31 of CTA and clarification made in the CBIC Circular No. 1022/10/2016-CX dated 06.04.2016 is very clear and determinative. In the instant case to classify a product under the fertilizer either the product should be Phosphorous dominance (superphosphate) i.e. Di-phosphorous Pentoxide (P205) containing weight 35% or more; (CTI- 31031100) or alike other (CTI-31031900) or should be phosphatic fertilizer other than superphosphates (CTI-31039000). As the composition of the product clearly indicate here that, it contains only 2.5% dry weight phosphorus and the magnesium and zinc are dominant. Therefore, the product cannot be classified in CTH-3103 as a phosphatic fertilizer. The CTH-3105 provides as per follows :- Mineral or Chemical Fertilizers containing two or three of the fertilizing elements Nitrogen, Phosphorous and Potassium; Other fertilizers. As the product has the ....
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....nts are also called minor or trace elements, but this does not mean that they are less important than macronutrients. Reply received from IARI on the subject, enclosed with the circular, may please be referred for further details. Inputs received from the trade indicates that these micronutrients are sold in the market as 'micronutrient fertilizer' supplying one or more of the eight essential nutrients listed above, namely iron to chlorine However, in the trade parlance sale of micronutrients as 'micronutrient fertilizers' would not lead to classification thereof under chapter 31 as fertilizers for the purposes of Central Excise Tariff. For classification under chapter 31, at least one of the elements, namely- nitrogen, phosphorus or potassium should be an essential constituent of the fertilizer as per chapter note 6 of chapter 31. 2.2 There is no specific heading in the tariff for classification of micronutrients. However, where the micronutrient is a separate chemically defined compound, it will be classifiable under the heading for that chemically defined compound under chapter 28 or chapter 29. For example, some of the sulphates of micronutrients are sp....
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....ote to the Chapter 31, it is apparent that :- i.a) Nitrogen, Phosphorous or Potassium are primary nutrients. i.b) (Calcium, Magnesium and Sulphur are secondary nutrients. i.c) Iron (Fc), manganese (Mn), zinc (Zn), copper (Cu), boron (B), molybdenum (Mo), nickel (Ni) and chlorine (Cl) are micronutrients. ii) Primary Nutrients (NPK) are required in the highest amount by the plants iii) Micronutrients are essential plant nutrients that are required in small quantity for plant growth and development. iv) The product Yara Vita Bud Builder has pre dominance of Magnesium (24%) and Zinc (10%) and the presence of Phosphorous (2.5%) is insignificant to ascertain the Tariff Classification. v) Considering the nature of the constituent and pre dominance of Magnesium and Zinc the product is not a good of Chapter Heading CTH-3103 (Phosphatic fertilizer) vi) The Circular No. 1022/10/2016-CX dated 06.04.2016 at Para 4 very categorically illustrates that "for any product to merit classification under CTH-3105 as other fertilizers, the product must have Nitrogen or Phosphorous or Potassium or their combination as an essential con....
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....ed under CETH 3824 as chemical products not elsewhere specified or included. 23. In addition, Note 1b to the Chapter 31 and explanatory note to the CTH 3105 also excludes chemical defined compounds which might be used as fertilizers from the ambit of the Chapter 31 and CTH 3105 relevant Note 1B to the Chapter 31 and relevant portion of the explanatory notes to CTH 3105 is also produced below: .............. Note 1 (b) separate chemically defined compounds other than those answering to the descriptions in Note 2(a), 3(a), 4(a) or 5 below]; or Relevant portion relevant portion of the explanatory notes to CTH 3105 The heading excludes: (a) Separate chemically defined compounds not specified in Notes 2 to 5 to this Chapter but which might be used as fertilisers, e.g., ammonium chloride which falls in heading 28.27. I observe the subject goods do not answer to the answering to the descriptions in Note 2(a), 3(a), 4(a) or 5 below. Also, the subject goods are preparation based on micronutrients and composed of the mixture of the chemical compounds as discussed in forgoing paras. The subject goods i.e YaraVita Bud Builder i.e 'Magnesiu....
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.... by Sr. No. 241 of the Schedule-I which covers CTH 3105 'other fertilizers'. The details of the description of the goods covered by the said Sr. Nos. is produced below for reference. Sr. No. Chapter/ Heading/ Sub- heading/ Tariff item Description of Goods 241 schedule 3105 Mineral or chemical fertilisers containing two or three of the fertilising elements nitrogen, phosphorus and potassium; other fertilisers; 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 Sr. No. and schedule Chapter/ Heading/ Sub- heading/ Tariff item Description of Goods 221 Schedule I 28 or 38 Micronutrients, which are covered under [serial number 1(g)| of Schedule 1, Part (A) of the Fertilizer (Control) Order, 1985 and are manufactured by the manufacturers which are registered under the Fertilizer (Control) Order, 1985 Accordingly, I observe that the above fact also corroborates that the subject goods which are preparation of micronutrients which are covered under [serial number 1(g)] of Schedule 1, Part (A) of the Fertilize....
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....TAT. b. CCEx. & ST Vs. Vikas Agro Products - 2017 (12) TMI 458 - CESTAT The applicant also relied on the case of CCE, Mumbai Vs. Aries Agrovet Industries - 2018 (6) TMI 1070 I observe that in the said cases the department proposed the classification of the Micronutrients under Heading 38.08 of the Central Excise Tariff Act, 1985 (CETA, 1985), which was not found to be the correct classification of the said products by the Hon'ble CESTAT. Therefore, the classification of the said products under Heading 31.05 of the CETA, 1985, adopted by the assesses, was upheld by the Hon'ble CESTAT. In the case of CCEx. & ST Vs. Vikas Agro Products - 2017 (12) TMI 458 - CESTAT and in the case of Hindustan Agro Insecticides v. CCE.& ST, Guntur [Final Order No. A/31234-31236/2017] the Hon'ble CESTAT has followed its earlier decision in the case of Aries Agrovet Industries Ltd. However, the issue in the present case is not limited to the classification of Micronutrients under Heading 38.08 or 31.05 only. The facts of the case are also different. Therefore, the decisions in those cases cannot be applied in the present case. Similarly, the applicant has also relied u....
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.... ix) The subject goods are excluded from chapter 31 and CTH 3105 in terms of the General explanatory note and Note 6 to the Chapter 31 read with CBIC circular No. 1022/10/2016-CX dated 6-4-2016. x) In terms of CBIC circular No. 1022/10/2016-CX dated 6-4-2016 as the essential character of the subject goods is that of mixture of micronutrients/multi-micronutrients having predominately trace elements viz. Magnesium, boron, and Zinc. It is classifiable under CTH 3824 as chemical products not elsewhere specified or included. xi) In terms of general explanatory notes to Chapter 31 the subject good is liable to fall under CTH 3824, being micronutrient preparation based on mixture of chemically defined compounds not specified anywhere. xii) In view of ii) to xi) above the subject goods correctly finds its place under CTH 3824. 31) In view of above, as the subject goods are micronutrient preparation and composed of mixture of chemical compounds. Also, the subject goods not separately defined chemically compounds and having specific heading under Customs tariff. Accordingly, based on composition as the subject goods do not having any specific heading under t....