Strict tariff conformity governs steel product classification; irregular goods were not strips and patta/patti classification was upheld.

Stainless steel goods could not be classified as strips under Item 25(12) of the Central Excise Tariff because the record did not show strict conformity with the tariff definition. The Tribunal relied on Board clarification and earlier rulings to distinguish strips from patta/patti, noting that irregular, uneven goods not in coil or flattened form do not answer the definition of strip. On the facts, there was no material to dislodge the lower appellate finding, so the goods remained classifiable under Item 25(8) as patta/patti and the Revenue failed to sustain the seizure-based adverse conclusion.

---

---

Issues: Whether stainless steel goods received by the assessee were classifiable as strips under Item No. 25(12) of the Central Excise Tariff or as patta/patti under Item No. 25(8), and whether the seizure and adverse finding could be sustained.

Analysis: The goods were described as circles and patta/patti, with some scrap arising in the process of manufacturing utensils. The Board's clarification and earlier Tribunal rulings were relied upon to distinguish strips from patties, noting that patties of irregular shape and uneven thickness, not in coil or flattened form, do not satisfy the definition of strip. The record contained no material to show that the assessee had received strips, and there was nothing to dislodge the finding of the lower appellate authority that the goods must strictly conform to the tariff definition before being treated as strips.

Conclusion: The goods were not shown to be strips classifiable under Item No. 25(12), and the classification under Item No. 25(8) was upheld in favour of the assessee.

Final Conclusion: The Revenue failed to establish any ground to interfere with the appellate finding, so the classification dispute was resolved against the Revenue and the assessee's position was sustained.

Ratio Decidendi: A product can be classified as a strip under the tariff only if it strictly conforms to the tariff definition, and in the absence of material proving such conformity, classification as patta/patti under the appropriate tariff entry must stand.

---