JUDGMENT

Banerjee, J.-This batch of appeals against the order of Customs, Excise and Gold (Control) Appellate Tribunal (CEGAT) pertain to classification of de-oiled rice bran extraction, niger seed extraction of topioca chips and sesame seed extractions as animal feed falling under Tariff Heading No.21 of the Second Schedule to the Customs Tariff Act, 1975. The core question thus relates to the factum of export duty being leviable thereon during the relevant period -CEGAT has answered that since these products are only ingredients of animal feed and not animal feed by themselves, the same would not come within the ambit of the term animal feed as detailed in the statute.

2. Shri Mukul Rohtagi, the learned Additional Solicitor General, appearing for the appellant, very strongly contended that differentiation, there might be as regards the product, but the factum of the product being an ingredient or a supplement to the animal feed would definitely bring it within the scope of "Heading 21" of the Customs Tariff Act - "Heading 21" does not, in fact, differentiate between the ingredients of animal feed and an animal feed neither the entire Tariff Act introduced such a differentiati