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Issues:
Classification of imported goods under ITC (HS) - 33029001.10 vs. 33029001.20. Analysis: Issue 1: Classification Dispute The appellants imported goods described as "synthetic perfumery compound" and claimed classification under ITC (HS) 33029001.10. The Revenue, based on a test report by the Chemical Examiner, sought classification under 33029001.20, requiring a special import license not produced by the appellants. The adjudication authority upheld the Revenue's classification, leading to appeals before the Tribunal. Issue 2: Interpretation of ITC (HS) Classification The dispute centered on whether "synthetic perfumery compounds" imported by the appellants differed from "synthetic perfumery preparations" as per the ITC (HS) classification. The appellants argued that the terms "preparation," "compound," and "mixture" were synonymous, supported by dictionary definitions and synonyms. The Revenue contended that "preparation" was distinct from "compound," justifying classification under 33029001.20. Issue 3: Tribunal's Decision The Tribunal, after considering the classification scheme of 33.02 and its sub-classifications, agreed with the appellants' interpretation. It found that "synthetic perfumery compound" was equivalent to "synthetic perfumery preparation," as affirmed by the Chemical Examiner. Consequently, the correct classification for the imported goods was determined to be 33029001.10, as claimed by the appellants. Conclusion The Tribunal set aside the lower authorities' decisions, allowing the appeals in favor of the appellants. It directed the Customs authorities to undertake necessary formalities, such as debiting Special Import Licenses, in accordance with the Tribunal's decision. The judgment clarified the classification dispute and emphasized the importance of interpreting terms within the context of the relevant classification scheme.
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