COROMANDEL FERTILIZERS LIMITED vs UNION OF INDIA AND ORS.

The Supreme Court dismissed the appeals, affirming that the fertilizers manufactured by the appellant do not qualify as mixed fertilizers under Notification No. 23 of 1970, as the manufacturing process creates additional substances. The Court held that the Explanation to the Notification is integral and must be considered in its entirety. Furthermore, the commission paid to selling agents does not constitute a trade discount under Section 4 of the Central Excise and Salt Act, 1944, and thus is not deductible for excise duty assessment.