MRS. MRIDULA BHATKAR, J.

The present appeal is filed directing against the judgment dated July 9, 2010 passed by the Second Bench of the Maharashtra Sales Tax Tribunal, Mumbai. In an appeal, the Tribunal accepted the case of the respondents - manufacturers and held that margarine is hydrogenated vegetable oil and therefore, it is classifiable under Schedule C, entry 100 meant for "vanaspati" (hydrogenated vegetable oil). Margarine is a product manufactured by the respondent used for cooking especially for bakery products. Different vegetable oils, viz., coconut oil, groundnut oil, mahua oil, maize (corn) oil, mango kernel fat, mustard oil, sunflower oil, palm oil, etc., can be used to get the margarine. Margarine is obtained by hydrogenation and emulsification. In the present appeal substantial question of law involved is :

"Whether the margarine is classified at Schedule C, entry 100 or Schedule C, entry 107(11)(F) liable at four per cent of tax or entry E1 and taxable at 12.5 per cent from February 1, 2008 under the Maharashtra Value Added Tax Act, 2002 ?"

The respondents are the manufacturers of margarine under the brand name lotus margarine 15 kg., golden seal margarine