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13. At the outset, it may be stated that in a generic sense "micronutrients" may be a kind of fertilizer in the functional sense but for the purposes of Central Excise Tariff they are excluded from the scope of CH 31.05 (fertilizers) by virtue of Chapter Note 6 which requires the term "other fertilizers" to include only those products used as fertilizers and containing N, P or K as an essential constituent which is not the case in respect of micronutrients.

14. Therefore, one needs to ascertain the composition of micronutrients. In this connection, we wish to quote from certain encyclopedias/chemical dictionaries as follows:

(i) According to the "Scientific Encyclopedia"

by Van Nostrand, "fertilizer" is a substance which is often a combination of substances of organic composition, natural or manufactured, in solid or liquid form. The "micronutrient"

consists of Boron (B), Copper (Cu), Iron (Fe), Manganese (Mn), Zinc (Zn) and Molybdenum (Mo).

15. The important thing to be noted is that N, P or K is not mentioned as an element of "micronutrient".

(iii) According to the "Scientific Encyclopedia"

by Van Nostrand, a `plant growth regulator' is essentially a chemical substance which is concerned with plant growth and which provides tonic to the plant growth. It is a plant hormone. It is an organic compound which controls growth.

(iv) According to the www.en.wikipedia.org "micronutrients" are vitamins and minerals.

Vitamin is an organic compound. Vitamins are classified by their biological activities and not by their structure. Vitamins have diverse bio-chemical functions including functions as hormones, therefore, plant hormones are also known as plant growth regulators. Plant hormones are made of chemicals that can vary in structure from one plant to another.

(v) According to the "McGraw-Hill Encyclopedia of Science & Technology" materials added to the soil or applied directly to crop, to supply elements needed for nutrition of the plant is called as "fertilizers". The chemical elements -

nitrogen, phosphorus and potassium are macronutrients or primary fertilizer elements which are required in greatest quantity.

Sulphur, calcium and magnesium are secondary elements necessary for the health of vegetation. They are required in lesser amounts as compared to macronutrients. The other elements include boron, cobalt, copper, iron, manganese, molybdenum and zinc.