JUDGMENT

(By G.R.SWAMINATHAN, J.)

This intra-court appeal is directed against the common order dated 24.10.2024 dismissing WP(MD)No.5414 of 2021 filed by the appellant herein. The writ petition filed by the appellant was taken up for disposal along with a few more writ petitions and given a common disposal by the learned Single Judge.

2.The appellant is engaged in the tobacco business. Their activity comprises the following : procuring raw tobacco from farmers, processing by drying, stripping and thereafter dipping it in jaggery water and subsequently mincing and packing for subsequent sale. Dipping the raw tobacco in jaggery water is called liquoring. This process is resorted to prevent mould and also to preserve the natural flavor of the tobacco.

3.Initially, the appellant was adding further ingredients to tobacco after it was processed as mentioned above like chilli/mint/other flavors and essences and marketed the product as “chewing tobacco” classifying the same under Central Excise Tariff Heading (hereinafter referred to as “CETH”) 2403 99 10. During May 2017, Government of Tamil Nadu issued a notification dated 23.05.2017 vide Gazette No.146, whereby, manufacture, storage, transp