CUSTOMS, EXCISE AND SERVICE TAX APPELLATE TRIBUNAL, CHENNAI REGIONAL BENCH – COURT NO. I Customs Appeal No. 40307 of 2016 (Arising out of Order-in-Appeal C.Cus.II No.877/2015, dated 03.09.2015 passed by the Commissioner of Customs, (Appeals – II), Custom House, Chennai 600 001)

TGV SRAAC Limited …..Appellant (Formerly, Sree Rayalaseema Alkalies and Allied Chemicals Ltd.)

40-304, 2^nd Floor, Krishna Jyothsna Complex Bhagya Nagar, Kurnool 518 004 Versus Commissioner of Customs ...Respondent Chennai – II Commissionerate Custom House No.60, Rajaji Salai, Chennai 600 001 AND Customs Appeal No. 40308 of 2016 (Arising out of Order-in-Appeal C.Cus.II No.876/2015, dated 03.09.2015 passed by the Commissioner of Customs, (Appeals – II), Custom House, Chennai 600 001)

TGV SRAAC Limited …..Appellant (Formerly, Sree Rayalaseema Alkalies and Allied Chemicals Ltd)

40-304, 2^nd Floor, Krishna Jyothsna Complex Bhagya Nagar, Kurnool 518 004 Versus Commissioner of Customs ...Respondent Chennai – II Commissionerate Custom House No.60, Rajaji Salai, Chennai 600 001 APPEARANCE:

Mr.K. Kumareshan, Advocate for the Appellant Ms. Anandalakshmi Ganeshram, Authorised Representative for the Respondent CORAM :

HON’BLE MR. M. AJIT KUMAR, MEMBER (TECHNICAL)

HON’BLE MR. AJAYAN T.V, MEMBER (JUDICIAL)

FINAL ORDER Nos.40098-40099/2026 DATE OF HEARING: 12.09.2025 &

07.11.2025 DATE OF DECISION: 19.01.2026 Per Ajayan T.V.

These two appeals preferred by the appellant TGV SRAAC Ltd. (formerly, Sree Rayalaseema Alkalies and Allied Chemicals Ltd.), albeit arising out of two different orders in appeal, both dated 03.09.2015, and heard on different dates; nevertheless involve the same issue, and are therefore disposed of by this common order.

2. The relevant facts are that the appellants had filed bills of entry for the clearance of “Lauric Acid” classified them under CTH 29157090 and availing exemption in terms of Notification No.12/2012-Cus. Sl.No.230 A and cleared the same. After clearance of the goods, the Department issued Show Cause Notices under Section 28 (1) of the Customs Act, 1962, proposing to change the classification to CTH 29159090, denying the benefit of Notification No.12/2012 ibid and demanding differential duties. After due process of law, the Adjudicating Authority rejected the classification made by the appellant, ordered reclassification under the proposed CTH, denied the benefit of the Notification and confirming the demand of differential duty along with applicable interest. Aggrieved by the same the appellant preferred appeals before the Commissioner of Customs (Appeals – II), Chennai who however, rejected the appeal and upheld the Order in Original. Aggrieved the appellants, having preferred these appeals, are now before this forum.

3. Shri K. Kumareshan, Ld. Advocate appearing on behalf of the appellants submitted that the appellant manufactures toilet soaps for which Lauric Acid is the raw-material. The Show Cause Notices issued alleging mis classification, proposing reclassification and demanding differential customs duty along with interest, in reply to which the appellant had submitted a write-up on Lauric Acid which was ignored.

4. The Ld. Counsel submits that the “assessed Bill of Entry” is an appealable order and Revenue has not reviewed the assessments of these Bill of Entry under Section 129D(2) of the Customs Act, 1962 and has not filed an appeal before the Appellate Authority. Reliance is placed on the decisions in Madhus Garage Equipments Vs. Commissioner of Customs (Appeals), Bangalore, 2006 (198) ELT 388 (Tri. – Bangalore). He would submit that the re- classification of Lauric Acid under CTH 29159090 is not based on any test conducted by Customs Laboratory or by any technical information / expert opinion.

5. It is submitted that the entry “others” appears in two places under Chapter Heading 2915. According to General Rules of Interpretation, ‘Lauric Acid” cannot be classified under CTH 29159090 which appears last in numerical orders as per Note 3