2000 (4) TMI 69

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....as been filed by the revenue against the finding of the Commissioner, which is as follows : "I have gone through the records of the case very carefully. I accept appellants' contention that Writing and Drawing inks have been used as synonymous terms as indicated by the description in the chapter Heading 32.15, and therefore, the sub chapter Heading 3215.10 will also cover drawing inks. However, I....

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....nk and other inks whether or not concentrated or solid. The chapter Heading 32.15 was bifurcated w.e.f. 1-3-1997 in sub-headings 3215 and 3215.90 covering writing inks and other inks respectively. Sub-heading 3215.10 covers only writing inks and rest all the inks viz. printing inks and drawing inks are classifiable under sub-heading 3215.10, drawing inks cannot be classified under this sub-heading....

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....k can not be taken in sub-heading 3215.10 though the same was stated as writing ink or drawing ink in main tariff Heading 32.15. Thus there is a distinction between writing ink and drawing ink and with this view only writing ink classified under sub-heading 3215.10 and was exempted from duty during the said period and that is why Govt. did not include the drawing ink in chapter sub-heading 3215.10....

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....97 have been sub-divided into 3215.10 for writing inks at nil rate and 3215.90 for other inks at 18 per cent. The heading covers printing inks, writing or drawing ink, other inks in whatever concentrations of forms. The scope of writing ink from the head notes under HSN is found to cover and include drawing inks; copying and hectographic inks, ball point pens, duplicating machines, typewriter ribb....