M/S I.D.L. CHEMICALS LTD. vs UNION OF INDIA & ORS.

The Supreme Court held that ammonium nitrate, used in the manufacture of explosives, is subject to excise duty under Tariff Item 68, as it does not qualify as a fertilizer under the Exemption Notification No. 164/1969 of the Central Excises and Salt Act, 1944. The Court affirmed the Central Board's classification of ammonium nitrate and upheld the demand for excise duty from the appellants. The Court dismissed the appellants' challenge to the notification excluding ammonium nitrate from the exemption, confirming the duty liability from 1st March 1975.