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TMI Blog2012 (5) TMI 609X X X X Extracts X X X X X X X X Extracts X X X X ..... e negative list. A plea was also raised that from the date of its inception, the assessee is a small scale industrial undertaking for which our attention was invited to various pages of the paper book. On the other hand, the learned Senior DR strongly defended the impugned order by submitting that the composition of soap and detergent is the same and the same has been mentioned in the negative list. 3. We have considered the rival submissions and perused the material available on file. The facts, in brief, are that the assessee is engaged in manufacturing of detergent on job work basis for Hindustan Lever Limited (HLL in short hereinafter). The raw material was also claimed to be supplied by HLL and the manufacturing process is done by the assessee. The assessee declared total income of ₹ 15,49,230/-, after claiming deduction of ₹ 6,63,956/- u/s 80IB of the Act in its return filed on 25.2.2004. The return was selected for scrutiny, therefore, pursuant to notice u/s 147 vide order dated 27.2.2010 the income was determined at ₹ 2,91,61,870/- (including disallowance of deduction of ₹ 6,63,956/-). However, under section 154 of the Act, necessary correction was ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... as the detergents are in the form of powder. Nothing prevented the legislature to specifically use the word "detergent powder" if it wanted to do so. The use of soap and detergent powder are always not the same and their chemical composition is also different, therefore, from this angle, we are not in agreement with the conclusion drawn in the impugned order. 3.4 The procedure for manufacturing soap and detergent which is as under :- SOAP AND DETERGENT MANUFACTURE Soaps and detergents are widely used in our society. Soaps are the product of the reaction between a fat and sodium hydroxide: fat + 3NaOH glycerine + 3 soap Soap is produced industrially in four basic steps. This article lists different steps because in the industrial processes described each of these is done over several process steps, but in principle it could be done in the three steps outlined here. Step 1 - Saponification A mixture of tallow (animal fat) and coconut oil is mixed with sodium hydroxide and heated. The soap produced is the salt of a long chain carboxylic acid. Step 2 - Glycerine removal Glycerine is more valuable than soap, so most of it is removed. Some is left in the soap to help make it sof ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... , it allows the oily dirt particles to form an emulsion with the water: the tails of many, surfactant molecules surround an oily dirt particle, forming a micelle with a drop of oil in the centre and the ionic heads of the surfactant molecules pointing outwards and hence keeping the micelle in the polar solution. This reaction is exothermic, and progresses quickly and efficiently at around 12SoC inside an autoclave type reactor. The most common fats and oils used are tallow (beef or mutton/beef blend), coconut oil, and palm kernel oil (Table 1). Different oils produce soaps of varying hardness, odour and lathering, so the ratios of the oils used are closely monitored to produce a blend with the most desirable characteristics for the most reasonable cost. However, pure soap is hard and easily oxidised, so various additives are added to correct this and to make a more aesthetically pleasing product. The first such "additive" is glycerine, which is produced in the saponification reaction. Glycerine makes the soap smoother and softer than pure soap. However, it is also much more valuable than soap itself, so only a minimum of glycerine is left in the soap and the remainder ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... iched by that formed in the saponification reaction. Step 2 - Lye separation The wet soap is pumped to a "static separator" - a settling vessel which does not use any mechanical action. The soap / lye mix is pumped into the tank where it separates out on the basis of weight. The spent lye settles to the bottom from where it is piped off to the glycerine recovery unit, while the soap rises to the top and is piped away for further processing. Step 3 - Soap washing The soap still contains most of its glycerine at this stage, and this is removed with fresh lye in a washing column. The column has rings fixed on its inside surface. The soap solution is added near the bottom of the column and the lye near the top. As the lye flows down the column through the centre, a series of 'rotating disks keeps the soap / lye mixture agitated between the rings. This creates enough turbulence to ensure good mixing between the two solutions. The rate of glycerine production is calculated and the rate at which fresh lye is added to the washing column then set such that the spent lye is 25 - 35 % glycerine. Glycerine is almost infinitely soluble in brine, but at greater than 35% glyce ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... Figure 2. Step 1 - Oil preparation The oils used most commonly are, as in the Colgate-Palmolive process, tallow and coconut oil. These are blended together and dried in a vacuum chamber. Once the oils are dry, bleaching earth is sucked by the vacuum into the chamber to remove any coloured impurities. The spent earth is landfilled and the oils stored ready for saponification. Step 2 - Saponification The mixture of bleached oils is mixed with spent lye from the washing stage (see below) and a caustic soda solution. The mix is heated and then left to settle into two layers. The neutral lye (which is now rich in glycerine) is pumped off and the mixture of soap and unreacted oils which has risen to the top is left in the pan. More caustic liquor is added to this and the mix reheated to saponify the remaining free oils. Step 3 - Washing The crude soap is then pumped to a divided pan unit (DPU) where it is washed by a counter-current of lye. This lye is a mixture of fresh brine solution and nigre lye (see below). The washed soap comes out the far end of the DPU and is sent to the fitting pans, while the lye comes out the near end and is pumped back into one of the saponification pan ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ients are added the mixture heats up as a result of two exothermic reactions: the hydration of sodium tripolyphosphate and the reaction between caustic soda and linear alkylbenzenesulphonic acid." The mixture is then further heated to 85°C and stirred until it forms a homogeneous slurry. Step 2 - Spray drying The slurry is deaerated in a vacuum chamber and then separated by an atomiser into finely divided droplets. These are sprayed into a column of air at 425°C, where they dry instantaneously. The resultant powder is known as 'base powder', and its exact treatment from this point on depends on the product being made. Step 3 - Post dosing Other ingredients are now added, and the air blown through the mixture in a fluidiser to mix them into a homogeneous powder. Typical ingredients are listed in Table 3. XI - Detergents- A - Soap-S Liquid detergent manufacture Step 1 - Soap premix manufacture Liquid detergent contains soap as well as synthetic surfactants. This is usually made first as a premix, then other ingredients are blended into it. This step simply consists of neutralising fatty acids (rather than fats themselves) with either caustic soda (NaOH) o ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... pumped to the crude settling tank where more salt separates out. XI - Detergents-A -Soap-I 0 Step 3 - Glycerine purification A small amount of caustic soda is added to the crude glycerine and the solution then distilled under vacuum in a heated still. Two fractions are taken off - one of pure glycerine and one of glycerine and water. The glycerine thus extracted is bleached with carbon black then transferred to drums for sale, while the water/glycerine fraction is mixed with the incoming spent lye and repeats the treatment cycle. ENVIRONMENTAL IMPLICATIONS Soap is designed as a product to be used once then flushed down the drain, so as expected the environmental implications of its manufacture are not nearly so great as many other chemical processes. There are two main areas of concern: the safe transport and containment of the raw materials, and the minimisation of losses during manufacture. The three main components of soap by both cost and volume are oils, caustic and perfumes. Oils and perfume are immiscible in water and if spilled create havoc, although the oils do solidify at room temperature. Transport of these products is by trained carriers, and the systems for pumpi ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... tergent products used in New Zealand are independently monitored and have been found to not be an environmental hazard. Detergent powder Detergent powder manufacture has some specific environmental issues associated with it that are not present in other areas of the industry. These are dust control and volatile organic emissions. Dust present during delivery and transfer of bulk powdered detergent (and powdered raw materials) is a potential problem. Dry and wet cyclones are used to filter out most of the dust, and all emissions are monitored. If the dust level in these does exceed acceptable limits, appropriate remedial action is taken. Dust levels in emissions must be kept below 50 mg m-3. The spray drying tower also releases volatile organics. These emissions are minimised by having tight specifications on what can be added as primary detergent active material. Any potentially hazardous material is added with the secondary actives after the tower so that it is not heated. Spot checks are done on the total hydrocarbon content of the exhaust gases using a flame ionisation detector. ROLE OF THE LABORATORY The laboratory monitors the formulation and specification of products fro ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... d detergent The product is typically tested for viscosity, pH, cationic detergent (fabric conditioner) content, enzyme content, conductivity (a measure of detergent stability), colour and perfume. Compiled by Heather Wansbrough from two articles, one from Ralph Laing (Colgate Palmolive) and the other from Paul Milson (Lever Rexona) and with reference to: • The Enclyclopcedia Britannica (15th ed); Encyclopredia Britannica, Inc.; 1979 • Selinger, Ben; Chemistry in the Marketplace (3rd ed.); Harcourt Brace Jovanovich; 1986 XI - Detergents- A -Soap- I 3 Soap is the product of reaction between a fat and sodium hydroxide (Fat + 3NaOH - glycerine + 3 soap). The whole process of both the items is indicative of factor that both the products are altogether different and commercially also known differently. 3.5 For claiming deduction u/s 80IB of the Act, as per subsection (2), the any industrial undertaking has to fulfil the conditions mentioned in the section. As per sub-clause (iii) the article so manufactured should not be in the list of the Eleventh Schedule and the product should be from a small scale industrial undertaking or an industrial undertaking referred to in sub ..... X X X X Extracts X X X X X X X X Extracts X X X X
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