description of goods are shown as “ tags, labels, printed bags, stickers, belts, buttons or hangers ”. It is stated that a similar entry is seen under Sl.No.167, which includes various items including “ fasteners ”. According to the petitioners, those items coming under Sl.No.167 enjoys only a limited benefit on account of the Entry in Column No.5 as condition No.21 which again is specified in the Annexure to the notification. According to the petitioners, they have been regularly importing snap buttons from the year 2002/2003 onwards, which would come squarely under Sl.No.140 and the duty was totally exempted, without any conditions attached to it. However, they were issued with a show cause notice dated 10/10/2005 stating that there was a misdeclaration of the goods that were imported. In the show cause, demand was made for `78,10,094/-. The matter was taken up with the Textile Commissioner and also Ministry of Textiles and by Ext.P4 dated 27/4/2006. A reply was received stating that under Sl.No.140, exemption is available only to buttons which are classified under sub heading 96062110 of Customs Tariff whereas the snap fasteners are covered under heading No.96061010. Pursuant to the show cause notice, order dated 31/8/2006 was passed as
