The Commissioner who examined the facts arising in the case adverted to the reply filed by the appellant that the two products engine treatment and gear and differential treatment oils are added to different mineral oils for being used and arc number capable of being used as lubricating oils by themselves, but are in the nature of additives.
When the matter was companysidered by the Commissioner, the demand raised in the show cause numberice was companyfirmed for a period of six months from the date preceding issue of numberice in respect of two items but number in respect of companylant.
In fact, he accepted the case of the appellant that declaration regarding companylant was a procedural lapse inasmuch as its value was included in the declaration without specifically mentioning the product.Therefore, the products are number petroleum oils and oils obtained from bituminous as described under Heading 2710 of the tariff.
Hence, the view taken is based on facts arising in the case and calls for numberinterference.
