Documentary evidence prevails over visual inspection in classifying imported goods as cannulae, securing exemption treatment.

Where import documents consistently described the goods as disposable cannulae, that documentary evidence prevailed over a Customs Appraiser's bare visual impression, which was not treated as expert opinion and was unsupported by testing. The record also did not show that the goods were complete hypodermic needles made up of a tube, hub and sheath. The goods were therefore treated as cannulae rather than bare needles, and the exemption under Notification No. 20/99-Cus. was accepted.

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Issues: Whether the imported goods were cannulae entitled to exemption under Notification No. 20/99-Cus. or bare hypodermic needles liable to duty under Heading 9018.32.

Analysis: The import documents, including the supplier's invoice, inspection certificate, memo of understanding, insurance documents and certificate of origin, consistently described the goods as disposable cannulae. Against this documentary material, the Revenue relied only on visual examination by the Customs Appraiser. The Appraiser's personal view was not treated as expert opinion, and no samples were sent for expert testing. The record also indicated that a needle is a composite item requiring a tube, hub and sheath, whereas the impugned goods were not shown to be complete needles.

Conclusion: The goods were held to be cannulae and not bare needles, and the exemption claim was accepted.

Final Conclusion: The assessment based on visual examination was set aside, and the import was treated as eligible for the claimed exemption.

Ratio Decidendi: Where documentary evidence consistently establishes the nature of imported goods, a mere visual opinion of the assessing officer, without expert corroboration, cannot displace that evidence.

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