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AUTHORITY FOR ADVANCE RULINGS

(CENTRAL EXCISE, CUSTOMS & SERVICE TAX)

NEW DELHI

 

 

PRESENT

Hon'ble Mr. Justice P. V. Reddi (Chairman)

                                                                            Mr.

Mr. A Sinha                               Mrs. Chitra Saha

                                                                                 (Member)                                   (Member)

 

Thursday, the Thirtieth August Two Thousand Seven

 

Ruling

Ruling No.AAR/02(CE)/2007

                         in

Application No.AAR/03(CE)/2007

 

Applicant                                                         M/s Lhoist India Private Limited

DBS House, Prescott Road, Fort

Mumbai-400001

                                                                                                                                   

Commissioner concerned                               Commissioner of Customs &

Central Excise, Bhubaneswar-I & II

           

Present for the Applicant                                 Mr. S. Ganesh, Senior Counsel,

                                                                        M/s Sujit Ghosh,  D.K. Rana and

                                                                        Sudipta Bhattacharjee, Advocates

Mr. Pieter Jonckheer (Director of applt.)

                                                                                   

Present for the Commissioner                        Mr. A.N. Sharma, Jt.CDR

concerned                                                       Mr. Deepak Garg, SDR

CESTAT, New Delhi

 

                                                                                                                                                                                                           

R U L I N G

(By Mrs. Chitra Saha)

 

 

          In the Application filed under Section 23C of the Central Excise Act, 1944, the Applicant M/s Lhoist India Pvt. Ltd., Mumbai, has sought an advance ruling on the following question:

 

"For the purposes of Central Excise laws of India read with the Central Excise Tariff Act, 1985, what should be the classification with respect to the finished product (i.e. high purity burnt Lime) proposed to be manufactured by the Applicant under the process enumerated in the facts contained in Annexure I."

 

2.         The applicant has submitted in Annexure I that high purity lime stone, i.e. calcium carbonate (CaCo3) is proposed to be imported.  This lime stone would be crushed and heated to high temperatures.  During the heating the calcium carbonate would decompose into carbon dioxide (CO2) and calcium oxide (CaO).  The carbon dioxide contained in the lime stone would escape leaving behind calcium oxide.  This calcium oxide, referred to as lime or quick lime or burnt lime would be further crushed to smaller sizes as per customers' requirements.  Apart from calcium oxide, the finished product, i.e. burnt lime would also have traces of certain impurities.  While calcium oxide would comprise 94 to 96% of the product, the other elements/compounds present in it would be magnesium oxide (MgO constituting less than 1.5%), silicon oxide (SiO2 accounting for less than 1%), sulphur (S which would be less than 0.05%) and R2O3 which has been clarified by the applicant, in the course of the hearing, to be aluminum oxide (Al2O3) which would constitute less than 0.5%.

 

3.         The applicant states that the two possible classifications of the high purity burnt lime in the First Schedule (hereafter referred to as the 'tariff') to the Central Excise Tariff Act 1985 are :  2522 under Chapter 25 and 2825 in Chapter 28.  Chapter 25 covers "Salt; sulphur; earths and stone; plastering materials; lime and cement".  The Tariff head 2522 under this Chapter covers "Quick lime, slaked lime and hydraulic lime, other than calcium oxide and hydroxide of heading 2825".  Note 1 of this Chapter reads as follows :

 

"Except where their context or Note 4 to this Chapter otherwise requires, the headings of this Chapter cover only products which are in crude state or which have been washed (even with chemical substances eliminating the impurities without changing the structure of the product), crushed, ground, powdered, levigated, sifted, screened, concentrated by flotation, magnetic separation or any other mechanical or physical process (except crystallization), but not products that have been roasted, calcined, obtained by mixing or subjected to processing beyond that mentioned in each heading."

           

4.         It is the applicant's submission that since the burnt lime is obtained by heating, i.e. calcining the raw material, lime stone, the finished product, i.e. burnt lime, gets excluded from Chapter 25 by virtue of    Note 1. The applicant further states that classification of burnt lime under Chapter 25 is also ruled out as 2522 specifically excludes calcium oxide and hydroxide of heading 2825. 

 

4.1       The applicant has referred to Chapter 28 which covers "Inorganic chemicals, organic or inorganic compounds of precious metals, of rare-earth metals, of radioactive elements or of isotopes." Note 1 of the said Chapter states that the headings of this Chapter apply only to separate chemical elements and separate chemically defined compounds, irrespective of whether or not they contain impurities.  Burnt lime comprising predominantly of the separate chemically defined compound, calcium oxide, which is a metal oxide, would get covered under the residuary sub-head 2825 90 90 falling under 2825 which covers "Hydrazine and hydroxylamine and their inorganic salts; other inorganic bases; other metal oxides, hydroxides and peroxides."

 

5.         In the course of the hearing on 17.7.2007, the applicant has referred to the definition of "impurities" in the Explanatory Notes (Volume I, page 261 Third Edition) on Chapter 28 of the Harmonized Commodity Description and Commodity System (hereafter referred to as HSN Notes) to state that the presence of the impurities magnesium oxide, aluminum oxide, silicon oxide and sulphur in the burnt lime does not take away the product from Chapter 28 in view of the following definition of the term "impurities" in the HSN Notes :-

 

"Separate chemical elements and separate chemically defined compounds containing impurities, or dissolved in water, remain classified in Chapter 28.

 

The term "impurities" applies exclusively to substances whose presence in the single chemical content results solely and directly from the manufacture process (including purification).  The substances may result from any of the factors involved in the process and are principally the following :

 

(a)              Unconverted starting materials.

(b)              Impurities present in the starting materials.

(c)               Reagents used in the manufacturing process (including purification).

(d)              By-products.

 

It should be noted, however, that such substances are not in all cases referred as "impurities" permitted under Note 1(a).  When such substances are deliberately left in the product with a view to rendering it particularly suitable for specific use rather than for general use, they are not regarded as permissible impurities."

 

Since the impurities in the final product burnt lime are all materials which were present in the "starting materials" i.e. lime stone and since no external substance has been added to burnt lime, the impurities fall in the category of "permissible impurities" in the above definition, contends the counsel for the applicant.  The applicant has also clarified that small amounts of the above materials were allowed to be left in the final product as removing them would be expensive and uneconomical.

 

5.1       In conclusion, the applicant has referred to orders of Tribunal and a judgement of the Supreme Court which have specifically excluded quick lime obtained by calcination of lime stone from the purview of Chapter 25 on account of the Note in that Chapter referred to above.  The First Schedule of the Central Excise Tariff Act 1985 has undergone several amendments in the past with changes in Chapter notes and in the descriptions of headings. The applicant claims that though the judgements cited were given in the context of the tariff as it existed at the relevant time, the conclusions in the said judgements still hold good in the context of the amended tariff.  The relevant decisions are :

 

·                    Steel Authority of India Ltd v CCE, Bhubaneshwar reported in 2004 (164) ELT 355 (Trib.)

·                    Brijbasi Lime Works v CCE, Indore reported in 1996 (88) ELT 681 (Trib.)

·                    CCE, Chandigarh v Nuchem Industries (P) Ltd reported in 1999 (105) ELT 711 (Trib.)

·                    CCE v Nuchem Industries Pvt Ltd reported in 1998 (99) ELT 197 SC

 

6.            Relying on the above case laws cited by the applicant, the Commissioners of Customs, Central Excise and Service Tax, Bhubaneshwar I & II concur with the conclusion of the applicant that the Chapter Note 1 precludes classification of burnt lime under Chapter 25. They further state that high purity burnt lime is not classifiable under any Chapter of the Central Excise tariff except Chapter 28, and that the arguments given by the applicant in support of classification under 2825 appear to be correct.

 

7.         A point put forward by the Senior Departmental Representative is that Chapter head 2825 covers only calcium oxide which is in the pure state.  An essential physical characteristic of such pure calcium oxide is that it is crystalline in nature.  This attribute of the product, which has not been clarified in the application, needs to be verified, specially since the silicon oxide and aluminum oxide present in the burnt lime are known to retard the process of crystal formation.  In response to the above, the applicant have submitted an affidavit dated 17.7.07 stating that the high purity burnt lime that they propose to manufacture would be "crystalline in structure in a cubic system" and that the presence of impurities does not affect/retard the crystallization of calcium oxide.

 

7.1       The Senior Departmental Representative has also submitted detailed technical literature on "Lime and Lime stone" appearing on pages 343-381 in Volume 14 of Encyclopedia of Chemical Technology by Kirk-Othmer and have referred to extracts from Wikipedia on calcium oxide.  It appears from a reading of the above literature that calcium oxide is known variously as lime, quick lime, burnt lime etc. and that the terms calcium oxide and lime/quick lime are used interchangeably.  This oxide is a white caustic and alkaline crystalline solid that finds extensive use in different fields.  While the most primitive use of calcium oxide has been in the building and the construction industry, it is also used for more sophisticated purposes such as for manufacture of chemicals, steel, paper, glass etc.  The literature also indicates that calcium oxide is most commonly manufactured by calcining lime stone (CaCo3) in kilns at high temperatures.  The heat chemically decomposes the lime stone into calcium oxide and carbon dioxide.  Quick lime has varying strengths of calcium oxide.  In USA, in the relatively pure chemical limes, the concentration of calcium oxide ranges between 93.25 to 98% and the concentration is less in lime manufactured outside USA (page 346 and 367 of Kirk-Othmer Encyclopedia.)

 

8.         Both the applicant as well as the Commissioners have relied on the note in Chapter 25 to rule out classification of burnt lime obtained by calcination of lime stone, in that Chapter.  The judgement of the Supreme Court in case of Nuchem Industries cited in this regard upholds a decision of the Tribunal to the effect that quick lime obtained by the process of calcination falls outside the scope of Chapter 25 by virtue of the Chapter note referred to above and that quick lime is not exigible to Central Excise duty.

 

8.1       The judgement of the Supreme Court pertains to demands for duty for the period 1985 to '89.  The Central Excise Tariff has undergone substantial amendments since then.  Chapter head 25.05 and the relevant note in Chapter 25 during 1986-89 read as follows :-


"25.05            2505.00            Mineral substances, not elsewhere specified

(including clay, earth colours, natural abrasive, sulphur, slate and stone), lime; plasters with a basis of calcium sulphate, whether or not coloured, but not including plasters specially prepared for use in dentistry"

 

Note 2

 

"Heading Nos.25.01, 25.03 and 25.05 cover only products which have been washed (even with chemical substances, eliminating the impurities without changing the structure of the product) crushed ground, powdered, levigated, sifted, screened, or concentrated by floatation, magnetic separation or other mechanical or physical processes (except crystallization) but not products that have been roasted calcined or obtained by mixing."

 

            At present, Chapter head 2522 and Note 1 of the said Chapter read as follows :-

 

"Heading 2522  - Quicklime, slaked lime and hydraulic lime, other than calcium oxide and hydroxide of heading 2825.

 

            252210 00                Quick lime               

            252220 00                Slaked lime

            252230 00                Hydraulic lime"

 

            Note 1

 

"Except where their context or Note 4 to this Chapter otherwise requires, the headings of this Chapter cover only products which are in crude state or which have been washed (even with chemical substances eliminating the impurities without changing the structure of the product), crushed, ground, powdered, levigated, sifted, screened, concentrated by floatation, magnetic separation or any other mechanical or physical process (except crystallization), but not products that have been roasted, calcined, obtained by mixing or subjected to processing beyond that mentioned in each heading."

 

9.         A reading of the above indicates that while Chapter head 25.05 earlier mentioned only "lime" in general terms, without mentioning its different varieties, including quick lime, the present tariff heading clearly mentions quick lime while excluding its predominant constituent viz. calcium oxide.  When the present tariff specifically includes quick lime which is being manufactured and bought and sold in the market, such a product cannot be said to be non-excisable, though the rate of duty is nil at present.  The fact that the product is obtained by calcination, a process debarred by Note 1 of Chapter 25, will not take away the quick lime from the purview of this Chapter as the said note has been amended after the judgement of the Supreme Court, and now begins with the preface "Except where the context or Note 4 to this Chapter otherwise requires....".  In the context of the present tariff which specifically mentions "quick lime" which can only be obtained by calcining lime stone, the said Chapter note cannot be held to exclude the said product from Chapter 25, as such an interpretation would render the entry "2522 1010 - quick lime" redundant.  The above conclusion is in conformity with HSN Note on Note 1 (page 210) which refers to goods, including quick lime, which remain covered under Chapter 25 despite having been subjected to processes not provided for by Note 1.  With the amendments in the tariff, the conclusions in the judgement in case of Nuchem Industries etc. no longer hold good.  Note 1 of Chapter 25 does not rule out classification of quick lime, which is another name for burnt lime under Chapter 25 of the existing tariff.

 

10.       The issue for decision is the classification of burnt lime having 94-96% of calcium oxide and some impurities.  Burnt lime is also known as quick lime and comprises predominantly of calcium oxide, which occurs in varying strengths. The Encyclopedia of Kirk-Othmer mentions that the purer varieties of quick lime available in USA have calcium oxide ranging between 93.25% to 98%.  "Quick lime" is specifically included under 25.22 of the tariff, while its main constituent, "calcium oxide", is classifiable under 2825 90 90 which covers metal oxides.  The description of 25.22 under which quick lime falls, however, specifically excludes calcium oxide of Chapter head 28.25  The question that now arises is which is the quick lime comprising mainly of calcium oxide that is classifiable under Chapter 25 and when does such quick lime get excluded from Chapter 25 on account of being calcium oxide of Chapter 28.

 

11.            Chapter 28 is a part of Section VI of the Tariff which covers "Products of the chemical or allied industries".  The Chapter 28 itself covers "Inorganic chemicals, organic or inorganic compounds or precious metals, of rare earths metals, of radioactive metals, of isotopes."  Calcium oxide is classifiable as a metal oxide under 2825 90 90.  Chapter Note 1 clarifies, inter alia, that this Chapter applies only to separate chemical elements and separate chemically defined compounds, whether or not containing impurities.

 

11.1            Chapter 25 which includes quick lime, on the other hand, forms a part of Section V which covers "Mineral products".  The said Chapter encompasses "Salt; sulphur; earths and stone; plastering materials; lime and cement" and Note 1 of this Chapter clarifies that this Chapter covers only such of the above products which are in the crude state or which have been subjected to some elementary processes such as washing, crushing, grinding, powdering, etc.  As mentioned earlier, the product quick lime has varying strengths of calcium oxide.  While the quick lime which is a less pure form of calcium oxide, is used in buildings, for white washing, cement manufacture etc., the purer versions with higher concentrations of calcium oxide find more sophisticated uses in steel making, manufacture of chemicals, paper, etc.  From a reading of the descriptions of goods in the Section, Chapter head etc. above , it would appear that the quick lime which is more akin to the "mineral product" lime in a relatively crude form, than to a "separate chemically defined compound", would merit classification under Chapter 25 whereas the purer versions containing higher concentrations of the separately defined chemical compound - calcium oxide and with very few impurities would get classified as metal oxide under Chapter 28.  It is relevant to mention here that Note 1 in Chapter 28 states that this Chapter contains separate chemically defined compounds, whether or not containing impurities.  The applicant, has also referred to the Explanatory Notes on HSN to show that the impurities present in their burnt lime, do not take away the product from the purview of Chapter 28.  The burnt lime proposed to be used in the manufacture of steel and  comprising of 94-96% of calcium oxide and permissible impurities, is more akin to the "separate chemically defined compound" - calcium oxide than to the mineral product lime in the crude state and would therefore merit classification as a metal oxide under 2825 90 90 of Chapter 28.

 

12.       The structure of the Central Excise Tariff is based on the internationally accepted nomenclature in Harmonized System of Nomenclature (HSN).  Supreme Court in the case of CCE, Shillong versus Wood Crafts Products Limited 1995 (77) E.L.T. 23 (SC) has held that when the tariff entry is patterned on HSN, disputes relating to tariff classification must, as far as possible, be resolved with reference to the HSN Explanatory Notes.  In the instant case, Explanatory Note on Chapter 25.22 supports the above classification.  HSN Note states that the quick lime falling in 25.22 is an impure calcium oxide obtained by calcining lime stone containing little or no clay and that the said heading excludes purified calcium oxide which falls under 28.25 (page 223).  Note of 28.25 (page 302) similarly clarifies that this heading covers only calcium oxide in the pure state in which there is practically no clay (emphasis supplied), iron oxide, magnesium oxide, etc.  The applicant has already clarified by referring to HSN Notes that the impurities in their burnt lime fall within the category of permissible impurities.

 

13.       To sum up, the burnt lime proposed to be manufactured by the applicant, which is in a crystalline form, contains 94-96% of the separately defined chemical compound calcium oxide and contains less than 1% of silicon oxide, less than 1.5% magnesium oxide, less than 0.05% of sulphur and less than 0.5% of aluminum oxide, is classifiable under sub head 2825 90 90 of Chapter 28 of the First Schedule to the Central Excise Tariff  Act 1985.

 

    Sd/-

(Chitra Saha)

Member

 

Per P.V. Reddi, J (Hon'ble Chairman) :-

            Broadly, I am in agreement with what the learned Member has said.  The justification for this addenda is only to supply emphasis to certain thoughts already reflected in her order.

 

1.         The applicant calls the product to be manufactured by it as "high purity burnt lime".  The trade name of that finished product, according to the applicant, is  steel grade lump lime which is mostly used in the steel industry.  It is known as high purity burnt lime for the reason that it will have high calcium oxide content of 94 to 96%.  According to the applicant, burnt lime/quick lime available in the domestic market in India usually has 75-85% purity in terms of calcium oxide content and in the case of industrial grade, it is  85-90%.   The end use of the proposed product is primarily in steel industry. 

 

2.            Wikipedia (the free Encyclopedia) refers to the fact that calcium oxide is "commonly known as burnt lime, caustic lime or quick lime".  The applicant also states that burnt lime is otherwise known as Quick lime.  In Encyclopedia of Chemical Technology by Kirk-Othmer, it is stated that the component of calcium oxide ranges between 93.25 and 98% in "Commercial quick limes".

 

3.         Limes of various descriptions contain predominantly calcium oxide.  But, some have comparatively less percentage and some have more.  The various expressions, viz, quick lime, burnt lime, pebble lime (physical shape of quick lime) are often used as inter-changeable expressions.  They broadly go by the description and belong to the genus of calcium oxide.

 

4.         If Quick lime stands alone in Chapter 25 without any qualification or exclusionary words, the product of the applicant would squarely fit into it.  By using the nomenclature 'high purity burnt lime', it cannot be taken out of the category of quick lime.             But, the task of classification is made difficult for the reason that the Heading 2522 excludes from the purview of quick lime calcium oxide of the Heading 2825.  Heading 2825,  among others, cover 'metal oxide'.  Calcium oxide being a metal oxide, it comes under Heading 2825.  More specifically, calcium oxide is to be brought under the residual Entry tariff item 2825 90 90 - "other" and it is liable to duty @ 16%.  Thus we have quick lime in Chapter 25 and calcium oxide in Chapter 28.  As already noted, quick lime is a common name for calcium oxide.  The overlapping commodities with interchangeable nomenclature are thus placed in two separate chapters.  Quick lime suffers no duty at present whereas calcium oxide attracts duty at 16%.  Then, how to understand these apparently similar items?  Where and how to draw the dividing line between the two? That is the puzzling question before us.  The only solution seems to be to distinguish them from the stand point of the degree of purity and their uses.  That is what has been done by the learned Member in para No. 11.1 of her ruling.

 

5.         Burnt lime containing practically nothing but calcium oxide with negligible quantities of impurities such as clay remaining in it and which is utilized for sophisticated industrial uses ought to be classified under the heading 2825 (T.I. 2825 90 90).  In the case of applicant's product, the calcium oxide content is said to be as high as 95%.  It may not be the calcium oxide in purest form, which is not known to be manufactured in our country.  Yet, the product burnt lime to be manufactured by the applicant is calcium oxide with little or negligible impurities.  It can be legitimately classified as calcium oxide under Heading 2825 as it is almost pure.  When we are called upon to distinguish calcium oxide from quick lime, this type of product which contains the calcium oxide - an inorganic compound, in almost pure state,  should be relegated to Heading 2825.   The Commentary/Explanatory notes in HSN referred to by the learned Member at paragraph 12 also lend support to this view point. 

 

6.         The first attempt of the applicant was to keep out quick lime and burnt lime from the purview of Ch. 25# That was sought  to be done by taking recourse to Note 1 to Ch. 25 and the decision of the Supreme Court in Collector of Central Excise vs. Nuchem Industries*.  The Supreme Court while interpreting the then existing Note 2 to Ch. 25 held that Quick lime and hydrated lime obtained by calcination would fall outside the scope of Ch. 25.  That conclusion was arrived at by the Supreme Court when the relevant Entry in Ch. 25 referred to 'lime' in general terms but not specifically Quick lime.   For the reasons stated by the learned Member in para 9, the ratio of that decision cannot be applied to the interpretation of the Heading and the Note as recast.   With specific inclusion of Quick lime in Ch. 25 as an excisable commodity.  Note 1 (corresponding to the then Note 2) cannot be invoked to exclude Quick lime from Ch. 25.  The prefatory  words in Note 1 "except where the context otherwise requires"  (inserted subsequent to the period with which the Supreme Court and CEGAT   was concerned) assume importance.  Note 1 obviously does not come into play where calcined product is specifically inserted as an excisable commodity though the rate of duty is nil.  The learned Senior Counsel for the applicant has practically conceded this position.  In sum,  I would like to clarify that the applicant's product  falls outside Ch. 25 not because Quick lime goes out of  Ch. 25 on account of Note 1 but because of exclusion clause contained in Heading 2522.

 

7.         It is interesting to note that at the relevant point of time when the Supreme Court decided the matter, lime was subjected to duty at 12% whereas now Quick lime attracts nil duty.  The reason for granting duty relief to Quick lime seems to be based on its non-commercial use and the class of consumers.

 

 8.            This is perhaps a rare case in which the applicant has come forward to pay duty for its product under Tariff Item 2825 90 90 instead of claiming duty relief available for quick lime.   Apparently, the applicant being convinced of the correct classification, would like to avert the risk of availing the benefit on the strength of decisions rendered in a different context and then facing a backlash at a later stage.

 

  Sd/-

(P.V. Reddi)

Chairman

 

Per Shri A. Sinha (Member) :-

 

            I have perused the ruling prepared by the learned Member and entirely agree with the conclusions reached therein.  I have also gone through the note of the Hon'ble Chairman, succinctly spelling out the rationale behind the ruling.  I also agree with the same as well as the reasoning given by the learned Member.

 

                                                                                                                           Sd/-

(A. Sinha)

Member

           

Pronounced by the Authority in the open Court on this 30th day of  August, 2007.

Registered /A D

 

F. No. AAR/03(CE)/2007                                                 Dated 30th August, 2007

 

(A) This copy is certified to be a true copy of the Ruling and is sent to :-

                       

 

1.        M/s Lhoist India Private Limited, DBS House, Prescott Road, Fort,

            Mumbai-4000012.  

2.      Commissioner of Central Excise, Customs & Service Tax, Bhubaneswar-I & II.

3.      Member(C.E), Central Board of Excise & Customs, North Block, New Delhi.

4.      Mr.A.N. Sharma, Jt. Chief Departmental Representative, Customs, Excise & Service Tax Appellate Tribunal, West Block-2, R.K.Puram, New Delhi-66.

5.       Guard File              

(Krishna A. Mishra)

Additional  Commissioner

Registered /A D

 

F. No. AAR/03(CE)/2007                                                Dated 6th September, 2007

 

(A) This copy is certified to be a true copy of the Ruling and is sent to :-

                       

 

1.         M/s Lhoist India Private Limited, DBS House, Prescott Road, Fort,

            Mumbai-4000012.  

2.      Commissioner of Central Excise, Customs & Service Tax, Bhubaneswar-I & II.

3.      Member(C.E), Central Board of Excise & Customs, North Block, New Delhi.

4.      Mr.A.N. Sharma, Jt. Chief Departmental Representative, Customs, Excise & Service Tax Appellate Tribunal, West Block-2, R.K.Puram, New Delhi-66.

5.       Guard File

 

(Krishna A. Mishra)

Additional  Commissioner

 

 (B)    In view of the provisions contained in Rule 25 of the Authority for Advance Rulings (Procedure) Regulations, 2005, permission of the Authority is accorded for publication of the Advance Ruling. Copy of the Advance Ruling is forwarded to: 

 

1.  Centex Publications Pvt. Ltd., 1512-B, Bhishma Pitamah Marg, Opp. ICICI Bank of Defence colony, New Delhi-110 003

2.  Deeparchie Publications, M-93, Marg-46, Saket, New Delhi-110 017

3.  Excise & Customs Cases, B-37, Sector-1, Noida-201301 (U.P.)

4.  Cen-Cus Publications, A-252, Shivalik, New Delhi-110 017

5.  Taxindiaonline.com Private Limited., B-XI/8183, Vasant Kunj, New Delhi-110 070

6.  Taxmann Allied Service Pvt. Ltd, 59/32, New Rohtak Road,  New Delhi-110005.

7.  www.allindiantaxes.com, 803, Kirti Shikhar, District Centre, Janakpuri, New Delhi-110058

                                                                                                                                                                           (Krishna A. Mishra)

Additional  Commissioner

# of Central Excise Tariff

* [1998] 99 ELT 197