Tariff classification turns on imported form and essential character, not intended end use for machinery parts.

Imported polyurethane foam rolls were classified by their form and essential character at the time of import, not by their intended use as filter material. The Tribunal held that goods presented as plastic foam sheets or rolls, and not cut or shaped as identifiable filter parts, retained their character as articles of plastic and could not be treated as parts of filtering machinery merely because they were meant for filtration. On that basis, Heading 39.21 applied and Heading 84.21 was rejected.

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Issues: Whether the imported polyurethane foam rolls, declared as filter segments or parts, were classifiable under Heading 84.21 as parts of filtering machinery or under Heading 39.21 as articles of plastic.

Analysis: The imported goods were examined in the form in which they were presented for assessment. The lower authorities found that the material was a plastic foam sheet or roll, not cut to shape or size as finished filter parts, and that its intended ultimate use could not control classification. The Tribunal followed its earlier view in the absence of any applicable contrary classification ruling for these goods and applied the principle that tariff classification depends on the nature of the goods at the time of import. The goods retained their basic character as polyurethane foam articles and did not acquire the identity of filter parts merely because they were meant for filtration use.

Conclusion: The goods were not classifiable under Heading 84.21 and were correctly assessed under Heading 39.21. The finding was against the assessee and in favour of Revenue.

Final Conclusion: The appeal failed on merits because the imported rolls were to be classified according to their imported form and essential character, not their intended end use.

Ratio Decidendi: Tariff classification of imported goods is determined by their form and essential character at the time of import, and intended end use does not override that classification unless the goods are shown to be identifiable parts of the claimed machinery.

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