( 1 ) THE short question that arises for consideration in the present case relates to the products of the respondents which they represent as being animal feed supplements. It is not in dispute that the products of the respondents consist of one or more vitamins mixed together with dilutants and these products are used in a small quantity for improving animals performance. The two competing entries are Entries 2302. 00 and 2936. 00. Entry 2302. 00 reads as follows: "2302. 00. Preparation of a kind used in animal feeding, including dog and cat food" the rate of duty for this is nil. Entry 2936. 00 reads as follows: the rate of duty prescribed is 15% for the vitamins.

( 2 ) THE Collector of Central Excise had come to the conclusion that the product did not fall under Entry 2302. 00 because the product had to be added in a small quantity to the main feed to get desired performance of the livestock or to enhance the performance of the livestock beyond the normal levels. He further observed that he would have accepted the plea of the assessees that the products were animal feed had the product manufactured by them been directly used as such for animal feeding. The claim of the responden