- (1.) Interpretation of the exemption notifications relating to heavy petroleum stock is for consideration in these appeals.
(2.) The appellants manufacture fertilizers. In the manufacture thereof, apart from other items they also use low sulphur heavy stock (hereinafter referred to as L.S.H.S.) which is regarded as heavy petroleum stock in respect of which exemption notifications have been issued.
(3.) Gujarat Narmada Valley Fertilizers Co. Ltd., had applied in 1983 for a licence in Form L-6 so as to obtain without payment of duty excisable goods, namely, L.S.H.S. which was to be used for the industrial process of manufacture of fertilizers. In the said application, it was stated that 30,000 metric ton of L.S.H.S. was to be used as feed-stock per month. The application also gave the manner of manufacture and it was inter alia stated that ammonia was manufactured using furnace oil and L.S.H.S. as feed-stock along with oxygen and steam by employing partial-oxidation process. Explaining the process further, it was stated that as a result of employing the said partial-oxidation process, gases are produced which are contaminated with soot. Thereafter, there are stages at which the gases initially produced are purified and ultimately when the impurities have been removed the gas is compressed and becomes liquid ammonia. This liquid ammonia is then used for the manufacture of urea fertilizers.;