Protein-Based Mass Weight Gainer Classified Under CTH 21061000 as Specific Description Prevails Over General Category

CESTAT allowed appeal regarding classification of imported Mass Weight Gainer under Customs Tariff Act. Product determined classifiable under CTH 21061000 (Protein Concentrates) rather than CTH 21069099 (residual category) based on GRI 3(a), which favors specific over general descriptions. Product primarily marketed as protein concentrate for muscle building, not medical recovery. Extended limitation period under Section 28(4) of Customs Act inapplicable as importer provided complete documentation at import, showing no suppression or misstatement of facts. Demand for differential duty set aside both on classification merits and limitation grounds. .....

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