Per Gowri Shankar : The question for consideration in this appeal by the Commissioner is whether cold galvanising compound, the product imported by the respondents, is consumer goods and therefore requires a licence for its importation. The Deputy Commissioner has held the goods to be consumer goods. His view was overturned by the Commissioner (Appeals) on appeal by the importer.

2. The product, manufactured by ZRC Products Company of the USA, it is stated in the catalogue of the manufacturer to be cold galvanizing compound, a liquid containing 95% zinc in the dried film that bonds to clean iron, steel or aluminium through electrochemical action to provide maximum protection against rust and rust creepage. Among the applications are stated to be: in place of hot-dip galvanizing, to repair damaged hot galvanizing, to regalvanize worn hot-dip surfaces, to protect weldments and to repair inorganic zinc surfaces. Some of the applications given in the brochure are off-shore rigs, long term protection in any fabrication of metal, manufacturing bridges, parabolic antennas, nuclear plants, transmission towers, industrial maintenance, public projects, such as bridges, construction of bu