narrates that sufficient material is not placed before the authorities in support of the appellant's changed view canvassed for the period of return. The clarificatory order dated 04.11.2009 refers to the commodities with which the appellant deals and the description as per the Bill of Entry. The competent authority examined the method by the description of the commodity as per the Bill of Entry. The fallacy in the said approach is that the appellant was also admitting that till August 2013, the appellant was treating Suprasec as Isocyanate, which is theoretically, and commercially incorrect. Therefore, by enclosing sufficient data for classifying supersec as a commodity falling under Polyurethane, the appellant agreed to change of HSN classification. It is also the case of the appellant that post-August 2013 the port of Entry accepted the very same goods as Polyurethane. For two reasons, the clarification issued in favour of the appellant, at least in the jurisdiction of this Court under Article 226, shall not be appreciated as a conclusive situation on the name of the commercial product characteristics, categorisation, and applicable rate of tax. As held by the Hon’ble Supreme Court, there is no estoppel against raising the contention on applicable
