Circular clarifying classification on the basis of packing is ultra vires.

Case:-M/s VVD AND SONS (PVT) LTD Vs CBEC AND THE SUPERINTENDENT OF CENTRAL EXCISE

Citation:- 2014-TIOL-2142-HC-MAD-CX

Brief Facts:- The writ petition is filed, declaring the impugned circular dated 3.6.2009 issued by the first respondent as null and void and contrary to the provisions of the Central Excise Act 1944 and ultra vires of Articles 14, 19(i)(g) and 21 of the Constitution of India and Section 37B of the Central Excise Act 1944 and the rules made thereunder and the Central Excise Tariff Act 1985. Under the impugned circular, the first respondent Government of India, Ministry of Finance, Department of Revenue classified the coconut oil packed in small container of sizes upto 200 ml under heading 3305 and consequently the second respondent Superintendent of Central Excise, City Range, Tuticorin, directed the petitioner to register themselves under his registration for the purpose of payment of duty of excise on the goods manufactured and cleared by the petitioner.

Few facts, which are relevant for consideration herein are as follows:

The petitioner is the manufacturer and distributor of coconut oil in various sizes of package. The first respondent has, vide circular bearing No.145/56/95-CX dated 31.8.1995 classified the coconut oil packed in small containers, the same is classifiable as a fixed vegetable oil under Chapter 15 or as a cosmetic preparation under Central Excise Tariff Act, 1985. It is stated therein that the coconut oil whether pure or refined and whether packed in small or large quantities merits classification under heading No.1503 as long as it satisfies the criteria of fixed vegetable oil laid down in Chapter note 3 of Chapter 15. It further says that if the containers bear labels/literature etc. indicating that it is meant for application on hair, as specified under Note 2 of Chapter 33 and/or if the coconut oil has additives (other than BHA) or has undergone processes which make it a preparation for use on hair as mentioned in Chapter Note 6 of Chapter 33, then the coconut oil may merit classification under Chapter 33. The same Chapter note 2 of Chapter 33 underwent a change consequent to the central excise tariff being changed to 8 digit tariff from the original 6 digits, so as to make the Central Excise Tariff aligning to HSN (Harmonised System of Nomenclature adopted world wide) and amendment was introduced in the Note 2 to Chapter 33 with effect from 1.3.2005.

It is not in dispute that the amended chapter note has done away with the requirement of label indicating the use as cosmetics which found place in the earlier Note 2 and the same was followed by the impugned circular bearing No.890/10/2009-CX issued by the first respondent vide F.No.102/05/2006-CX-3 dated 3.6.2009 under section 37B of the Central Excise Act, 1944 and the communication of the second respondent in O.C.No.2106/2009 dated 13.7.2009, whereby, coconut oil packed in containers upto 200 ml is classified under heading 3305 and consequently the petitioner is directed to register themselves under his registration for the purpose of payment of duty of excise on the goods manufactured and cleared by the petitioner. Questioning the validity of the same, the present writ petition came to be filed by the petitioner before this court.

Appellant contentions:-The validity of the impugned circular is sought to be questioned on the side of the petitioner by contending that:
(i) the first respondent Central Board of Excise and Customs (CBEC) has no jurisdiction to issue orders or circular in exercise of power under section 37B of the Central Excise Act, 1944, which is contrary to
the decisions of the Tribunal;
(ii) the classification made by the impugned circular on the basis of the quantum of packing of coconut oil that too on the basis of the alleged market survey conducted by them is not correct and proper;
(iii) the impugned circular is violative of Article 14 of the Constitution of India.

Insofar as the first ground is concerned, it is contended that section 37B only enables CBEC to issue orders or instructions or directions for the purpose of uniformity in the classification of excisable goods or with respect to levy of duties of excise on such goods and such power cannot be exercised to issue any orders or instructions to overturn the decision of the Tribunal, which power is exclusively vested with the High court or Supreme court depending upon the nature of the dispute. In short, it is contended that Section 37B cannot be used to interfere with the exercise of quasi judicial power of adjudication. The learned counsel for the petitioner, in support of such contention, relied on the following decisions:

(i) Pioneer Miyagi Chemicals 2000 (116) ELT 441 (Mad);
(ii) Faridabad Iron and Steel Traders Association 2004 (178) ELT 1099 (Del);
(iii) Sarabai Chemicals 1995 (76) ELT 34 (Guj) and
(iv) Marico Industries 2012 (282) ELT 180 (Ker).

It is also contended that in view of the decisions of the Tribunal on earlier occasions, the classification made by the impugned circular on the basis of the packing of the coconut oil is not correct. It is further argued that the impugned circular, apart from being bad for want of jurisdiction the classification on the basis of packing, results in hostile discrimination of identical goods in violation of the equality clause in Article 14, besides, failing to satisfy the twin tests laid down by the Hon'ble Supreme Court. It is sought to be argued on the side of the petitioner that the classification on the basis of packing has no nexus to the object sought to be achieved and when the law making authority has not chosen to make one such classification, such classification cannot be introduced through the circular, whereby indirectly legislating under section 37B of the Act, which is in excess of jurisdiction vested upon the authority concerned.

Respondent Contentions:- Per contra, the learned counsel for the respondents department would submit that the market survey conducted, showed that smaller packs are normally used as hair oil by the consumers and the same warrants re- examination of the earlier circular issued in 1995 and in order to ensure the uniformity in the assessment of the product, coconut oil packed in retail packs which are generally used by consumers as hair oil, is classified under heading 33.05 and not under Chapter 15 and the same does not amount to reclassification of the coconut oil and such classification is also supported by amended Note 2 of Chapter 33 and how a product is generally being used by the consumer is the only criteria. It is also contended on the side of the respondents that as it is well settled that classification can be made even on the basis of weight, the classification made on the basis of nature of usage cannot be construed as discrimination and as violation of equality under Article 14 of the Constitution of India.

Reasoning of Judgment:- Heard the rival submissions made on both sides. The relief sought for herein is against the classification of coconut oil packed in retail packs upto 200 ml under the heading 3305 so as to attract payment of excise duty. It is not in dispute that the coconut oil was, before amendment of Chapter note 2 of Chapter 33 of CETA with effect from 1.3.2005, classified as vegetable oil and brought under Chapter 15 of CETA. Whereas, the same was, after amendment classified as hair oil and brought under Chapter 33 of CETA. It is equally not in dispute that this revised classification was based on packing, which is according to the authority, of such kind sold by retail for use as cosmetics.

10. For better appreciation, Chapter Note 2 of Chapter 33 of CETA before and after amendment is extracted hereunder:

Before amendment:

"Heading Nos.33.03 to 33.07 apply, inter alia, to products, whether or not mixed (other than aqueous distillates and aqueous solutions of essential oils), suitable for use as goods of these headings and put up in packings with labels, literature or other indications that they are for use as cosmetics or toilet preparations or put up in a form clearly specialised to such use and includes products whether or not they contain subsidiary pharmaceutical or antiseptic constituents or are held out as having subsidiary curative or prophylactic value."

After amendment with effect from 1.3.2005:

"Headings 33.03 to 33.07 apply, inter alia, to products, whether or not mixed (other than aqueous distillates and aqueous solutions of essential oils), suitable for use as goods of these headings and put up in packings of a kind sold by retail for such use."

The reading of Chapter Note 2 of Chapter 33 before and after amendment as extracted above, would undoubtedly go to show that before amendment, the coconut oil was treated as suitable for use as fixed vegetable oil or as cosmetics not depending upon the packing but on the labels, literature or other indications that they are for use as cosmetics or toilet preparations or put up in a form clearly specialised to such use. Whereas, the same was, as per the subsequent amendment, revised by solely depending upon the packing.

The first ground of attack against the validity of the impugned circular is that the impugned circular is in excessive exercise of jurisdiction vested on the authority concerned under section 37B of the Central Excise Act, 1944. It is contended herein that the first respondent Board cannot be permitted to issue one such circular to nullify or get over the effect of decisions of the Tribunal on earlier occasions on the same issue and the same amounts to interference with the quasi judicial power of the Assessing Officer under the Act, which is the domain of the appellate authority. The learned counsel for the petitioner would, in support of his contention that the Tribunal rulings will prevail over the circular if the same is contrary to the Tribunal rulings, cited the following authority reported in Pioneer Miyagi Chemicals v. Central Board of Excise and Customs, New Delhi, 2000 (116) ELT 441 (Mad) , wherein, our High Court has in paras 9 and 10 categorically held that

"While admitting that the legislature could set right the defects that may be pointed out by the Supreme Court or High Court, but neither the first respondent nor any other respondent had the authority to nullify the judicial pronouncements". "The first respondent which is empowered to issue circulars under section 37B cannot nullify the effect of the judicial decision of the Tribunal as well as High court and the Supreme Court". In the same para 10, the decision of Gujarat High Court in Indichem v. Union of India reported in 1996 (88) ELT 35 (Guj) was referred, in support of the petitioner's contention that Section 35C(4) provides mandatory that the decision of the Appellate Tribunal shall be final save as provided under section 35G or 35L. In paras 35 and 36 of the same decision, our High court has discussed in detail the scope of section 37B of the Central Excise Act, 1944, which enables the Board to issue directions with respect to classification of excisable goods and with respect to levy of excise duty on such goods. It is observed that the Board has got the powers to issue purely administrative directions or such other directions, so long as it does not interfere with the quasi judicial powers of the assessing officers, under the Act or for that matter, the appellate authority under the Act. Our High court in paras 35 and 36 further observed that the circular issued by the first respondent Board cannot override the Act nor it could run counter to the statutory provisions nor it binds the quasi judicial authorities and that, the first respondent has neither the authority nor jurisdiction to issue the circular which runs counter to the judicial pronouncements.

Similar view was also expressed in yet another judgment cited on the side of the petitioner in Faridabad Iron and Steel Traders Association v. Union of India 2004 (178) ELT 1099 (Del), wherein, the Delhi High court was of the view that according to the spirit of Section 37B, circulars or directions can be issued in order to achieve the object of uniformity and to avoid discrimination and such circulars bind the officers only when they act in their administrative capacity and the quasi judicial functions cannot be controlled by executive actions by issuing circulars. The Delhi High Court has gone to the extent of saying that the Board's circulars instructions or directions cannot in any manner interfere with quasi judicial powers of the Assessing Officers and the officials exercising quasi judicial powers must ignore any circular or direction interfering with their quasi judicial functions. It is also observed therein that when any authority is conferred with the power to determine certain question in judicial and/or quasi judicial manner, the authority is required to exercise the power conferred upon him as per his own discretion and cannot be influenced by any directions, instructions or the circulars that may be issued by any other agency and the circular issued by the respondents cannot be permitted to interfere with the discretion of the judicial and quasi judicial authorities. In the same judgment, the Delhi High court has categorically observed that the power to impose tax is essentially a legislative function and according to our constitutional scheme, it cannot be delegated and the Excise Duty which the legislature intends to impose must be imposed directly in accordance with law and not through any circular. In such event, the circular deserves to be quashed.

Next judgment relied on the side of the petitioner is the decision rendered by Gujarat High Court in Raymon Glues & Chemicals v. Union of India, 2000 (117) ELT 29 (Guj), wherein, Gujarat High court following the decision of the Division Bench of same Court in Indichem v. Union of India (cited supra) and judgments of the Hon'ble Supreme Court reported in AIR 1961 SC 182 and AIR 1992 SC 711, has observed that no orders, instructions or directions can be issued so as to require any Central Excise Officer to make a particular assessment or to dispose of a particular case in a particular manner so as to interfere with the discretion of the Collector of Central Excise (Appeals) in the exercise of his appellate functions. It is categorically held that Section 37B does not empower or authorise the Board to issue directions which are contrary to the decision rendered by the Tribunal. It is further held that in the event of the Board not being in agreement with the views expressed by the Tribunal, the remedy available to the Board is to carry the matter in appeal and it cannot be made to be nugatory by issuing circular and the Board cannot use its authority or powers in issuing circulars in a manner, which may have ultimate effect of nullifying the decision of CEGAT as if taking the order in Appeal and reversing the order, exercising the powers, as if it is sitting as Apex Court. Thus, all the three High courts in the decisions cited supra, well laid down the legal principle regarding the scope of Section 37B and the nature of the circular that can be issued under the relevant provision of law. The observations of three High Courts in the decisions as referred to above, would make it clear that the nature of the orders, instructions, directions issued under section 37B is only for limited purpose and while doing so, it cannot over ride or nullify or get over the decision of the Tribunal, by exercising any appeal power or indulged in legislating.

The learned counsel for the petitioner would at this juncture draw the attention of this court to the decisions rendered by the Tribunal, one of which is confirmed by the Hon'ble Apex court regarding the same classification issue and would argue that the impugned circular intends to get over the Tribunal decision and is hence without jurisdiction and is bad in law:

(i) Final order no.638/08 dated 25.6.2008 in M/s. Madhan Agro Industries (P) Limited case, Chennai (CESTAT, SZB, Chennai);

(ii) Aishwarya Industries, Pondicherry

(iii) Capital Technologies Limited and others v. Commissioner of Central Excise and Service Tax, Tirupathy, Bangalore as confirmed by the Hon'ble Supreme court by dismissing the appeal;

(iv) M/s. Raj Oil Mills Ltd and others v. Commissioner of Central Excise, Mumbai. In all the cases cited above, the Tribunal was of the view that the coconut oil did not fall under Chapter 33 and Note 2 of Chapter 33 excluded coconut oil from its purview.

In the first case M/s.Madhan Agro Industries (P) Limited, the following earlier decisions of the Tribunal were referred to:

(a) Amardeo Plastic Industries v. CCE, Belapur, 2007 (210) ELT 360 (Tribunal, Mumbai);
(b) Kothari Products Ltd v. CCE, 2002 (139) ELT 633 (T)
(c) Srikant Sachets Pvt. Ltd v. CCE, 2005 (180) ELT 401 (T)
(d) CCE v. Essen Products (I) Ltd, 2006 (200) ELT 342 (T),

wherein, the Tribunal observed that Chapter Note 2 of Chapter 33 excluded such oils form its purview. By way of clarification, it is further held that the bottles containing coconut oil did not indicate their use on hair and the bottles and other packings in which coconut oil was filled were not in form clearly specialised to the product's use as 'Hair oil". Examples were also given in the same order to bring it under HSN Note expression 'form clearly specialised to such use" such as, nail varnish put up in small bottled along with brush required for applying the varnish; packing of a talcum powder containing of puff for applying on the face or a bottle of mascara or eyeliner containing a specialised brush for application of the same etc. It is found that packing of coconut oil was not of the specialised type as in the cases cited above or which could be solely and exclusively said to be meant for application on hair only.

In Capital Technologies Ltd and others v. Commissioner of Central Excise and Service Tax, Tirupathy case, the issue involved therein was in respect of repacking the goods of brand "New Nihar Naturals" declared to be edible grade coconut oil received from HLL into small retail packets. The Tribunal, after considering the submission, arrived at a conclusion that the post amendment to Central Excise Tariff Act i.e, from 28.2.2005, the products which are identical to the products in question were classifiable under Chapter 15 of the Central Excise Tariff Act and there was clear indication that the goods are of edible grade coconut oil and that the assessee has always represented to the market, the product as an edible grade coconut oil and not as a hair care oil and no contrary evidence was produced on the side of the Revenue that the products are not represented to market as edible grade coconut oil. The Tribunal, on the basis of such findings as referred to above and following the judicial pronouncement on identical issue in M/s. Madhan Agro Industries (P) Ltd, was inclined to hold that the impugned order was not sustainable and accordingly set aside the same. When the correctness of the same was challenged before the Hon'ble Supreme Court, the Apex court, after condoning the delay in filing the appeal, dismissed the appeal, thereby confirming the order of the Tribunal.

As rightly argued by the learned counsel for the petitioner, the respective Tribunals in the decisions referred to above are of the view that coconut oil is excluded from the purview of Chapter Note 2 of Chapter 33 and the same falls under Chapter 15 in the absence of any indication to show that it is meant for the use as cosmetics and irrespective of packings and the first respondent has no jurisdiction to issue circular, which has the effect of nullifying the decisions rendered by the Tribunal. The learned counsel for the petitioner also cited another decision in Shalimar Chemical Works Ltd v. State of Assam and others, (2012) 50 VST 253 (Gau), wherein the Gauhati High Court was of the view that construction favourable to the assessee to be adopted in preference to other possible construction.

Per contra, the learned standing counsel for the Revenue would rely on market enquiries, which according to the Revenue, revealed that smaller packs are normally used as hair oil by the consumers, as such, the same is classified under heading 3305 and not under chapter 15. It is contended by the learned standing counsel for the Revenue that though the small retail packs may be used as edible oil in some cases, the criteria is as to how the said product is generally sold in retail packs and the impugned circular is issued only to maintain uniformity in classification of the goods. It is also argued that by the impugned circular, the petitioner is not the aggrieved person and the central excise duty is collected from only the ultimate consumer, irrespective of the quantum of oil being sold. It is further argued on the side of the respondents that the dispute regarding the purpose of use on the basis of the quantity purchased cannot be the subject matter of decision by this court under extraordinary jurisdiction. The learned counsel for the respondents, in support of such contention, also cited the judgments in:

(i) (1988) 71 STC 173: (1988) 3 SCC 579 (Jain Exports Pvt. Ltd v. Union of India);
(ii) (2010) 10 SCC 503 (LML Limited v. Commissioner of Customs)
(iii) Civil Appeal No.3221/2010 dated 12.4.2010 (Raj Kumar Shivhare v. Assistant Director, Directorate of Enforcement and amp and another);
(iv) AIR 2013 SC 30 (Rohitash Kumar and others v. Om Prakash Sharma and others);
(v) Kaleesuwari Refinery Pvt. Ltd v. Central Board of Excise and Customs and others in WP.Nos.7705 and 7706 of 2011 (Madras High court);
(vi) Mahakaushal Builders Welfare ...v. Superintendent of Customs and Central Excise) (Madhya Pradesh High Court);
(vii) 2011 (272) ELT 163 (Commissioner of Sales Tax v. Dev Enterprises Limited) (Bombay High Court).

In all these cases, the Tribunal, High Court and the Hon'ble Supreme court were of the view that the issue relating to classification of goods involves technical and scientific evaluation and analysis and that unless something patently wrong is demonstrated, while classifying a particular product, the Court should not interfere and that, a legal enactment must be interpreted in its plain and literal sense as that is the first principle of interpretation etc. However, the same are not applicable to the facts of the present case, wherein, the issue involved relates to reclassification on the basis of the quantum of packing that too by way of circular issued by the first respondent, as such, the judgments cited on the respondents side are inapplicable to the facts of the present case. In the judgment passed by learned sister judge of this Court in Kaleesuwari Refinery Pvt. Ltd case, the attention of the learned sister judge was not drawn to the decisions rendered by the respective Tribunals regarding classification already issued and the same led to the judgment against the assessee. This court is of the view that as it has been consistently held that as the power under section 37B cannot be used to interfere with the exercise of quasi judicial power of adjudication and as the impugned circular is contrary to well settled principles, the impugned circular is bad for want of jurisdiction.

Other grounds on which the impugned circular is sought to be challenged are that:

(i) it is hostile discrimination of identical goods in violation of the equality clause enshrined in Article 14 of the Constitution of India;
(ii) it does not satisfy the twin tests to ascertain whether the classification is permissible or not; and (iii) it results in indirectly legislating under Section 37B of the Act.

Insofar as the second ground regarding violative of equality clause enshrined in Article 14 of the Constitution of India, is concerned, it is contended before this court that the department has not chosen to levy duty on coconut oil packed in the containers above 200 ml upto 20kgs, which are purchased and consumed by financially well to do people and the department has chosen to levy and collect service tax on coconut oil sold in small packs containing 50ml and 100ml and 200ml which are predominately purchased and consumed by economically poor and downtrodden, who cannot afford to buy even in such small packs and the same is against the principle enshrined in Article 14 of the Constitution of India and the same is hence illegal. To elucidate such stand taken on the petitioner's side, the judgment reported in AIR 1967 SC 1458 (State of Andhra Pradesh and another v. Nalla Raja Reddy and others) is relied on before this court. The Hon'ble Apex court in that decision was of the view that while the Article prohibits discriminating, it permits classification. It is observed that a statutory provision may offend Article 14 of the Constitution both by finding differences where there are none and by making no difference where there is one. As rightly argued by the learned counsel for the petitioner, the first respondent authority has by the impugned circular, classified the coconut oil packed in 200 ml and above 200ml under different chapters, when the coconut oil contained in the container upto 200 ml and above 200 ml remains the same, without any difference between the two and the levy of tax to the same product contained in the retail packet upto 200 ml and exemption from payment of duty in respect of the same product packed in the container above 200ml does not amount to classification, but amount to discrimination. Further, as the coconut oil manufactured and marketed by the petitioner comprise of more edible variety, the fact that it can also be used as hair oil, does not render the classification made herein as reasonable one.

This court finds some force in the contention raised on the side of the petitioner that coconut oil in such small packs being purchased by poor people both for personal and domestic use, the nature of the use favourable to the assessee to be adopted in preference to other use as held by Gauhati High court in Shalimar Chemical Works Ltd case. At the risk of repetition, it is stated that the small packs, having been mainly meant for economically poor and down trodden, the presumption that it is used as cosmetics than as edible oil, has no rhyme, reason or logic in the same. By doing so, the poor purchaser of small packs are burdened by levying additional tax.

As far as the ground regarding twin tests is concerned, the Hon'ble Apex court has laid down that the validity of the classification has to satisfy two tests viz.,

(i) classification must be founded on an intelligible differential which distinguishes persons or things that are grouped together from others left out of the group;
(ii) that the differential must have a rational relation to the object sought to be achieved by the statute in question. However, this court does not find any rational between the classification made and the object sought to be achieved on such classification.

As already referred to, small packs will be normally purchased by consumers with lesser financial ability to pay. If the object to be achieved by such classification is to bring uniformity, the classification leads to more disparity among the purchasers and the same is hence unreasonable and arbitrary. It is also not indicated in the impugned circular as to how the uniformity can be achieved by bringing the same coconut oil based on the packing under two different headings. Except stating that the market survey is the basis for arriving at the conclusion that upto 200ml pack is being purchased by the consumers for use it as hair oil, the classification made through the impugned circular is unfounded and without any basis.

Regarding the third ground that the impugned circular issued under section 37B of the Act amounts to indirectly legislating, this Court is inclined to reiterate the observation of the Delhi High court in Faridabad Iron and Steel Traders Association v. Union of India case as referred in the foregoing paragraph. As rightly argued by the learned counsel for the petitioner, the first respondent has through the impugned circular, proceeded to impose tax for the coconut oil packed in the container upto 200ml and thus usurped the function of the legislative body. The first respondent has sought to impose duty indirectly, which, the legislature would intend to impose directly in accordance with law. Thus way, the same amounts to indirectly legislating, which is not legally permissible.

Thus, for the discussions held above, the impugned circular issued by the first respondent is held to be arbitrary, unreasonable, without jurisdiction, null and void and contrary to the provisions of the Central Excise Act, 1944, and ultra vires of Articles 14, 19(i)(g) and 21 of the Constitution of India and Section 37B of the Central Excise Act 1944 and the rules made thereunder and the Central Excise Tariff Act 1985, as such, the petitioner is entitled to the declaratory relief as sought for in this writ petition in respect of impugned circular passed by the first respondent.

In the result, the writ petition is allowed as prayed for. No costs. Consequently, connected miscellaneous petitions are closed.

Decision:-Writ Petition is allowed.

Comment:- The crux of the case is that Section 37B only enables CBEC to issue orders or instructions or directions for the purpose of uniformity in the classification of excisable goods or with respect to levy of duties of excise on such goods and such power cannot be exercised to issue any orders or instructions to overturn the decision of the Tribunal, which power is exclusively vested with the High court or Supreme court depending upon the nature of the dispute. The Tribunal rulings will prevail over the circular if the same is contrary to the Tribunal rulings. CBEC, which is empowered to issue circulars under section 37B cannot nullify the effect of the judicial decision of the Tribunal as well as High court and the Supreme Court.

Consequently, it was concluded that the circular clarifying that the coconut oil packed in the containers upto 200 ml will be classifiable under chapter 33 as they are generally used for application on hair is discriminatory and void. This is for the reason that the department has not chosen to levy duty on coconut oil packed in the containers above 200 ml upto 20kgs, which are purchased and consumed by financially well to do people and the department has chosen to levy and collect service tax on coconut oil sold in small packs containing 50ml and 100ml and 200ml which are predominately purchased and consumed by economically poor and downtrodden, who cannot afford to buy even in such small packs and the same is against the principle enshrined in Article 14 of the Constitution of India and the same is hence illegal. The object of classification should to bring uniformity but the classification by the circular leads to more disparity among the purchasers and the same is hence unreasonable and arbitrary.

Prepared By:Meet Jain

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PJ/CASE LAW/2014-15/2535

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