Polished steel balls classification under Heading 84.82 confirmed where Chapter Note tolerance and further working were satisfied.

Polished steel balls satisfying the diameter tolerance in Chapter Note 6 of Chapter 84 fall under Heading 84.82 of the Central Excise Tariff. The goods were found to meet the prescribed maximum and minimum diameter limits, and their polishing showed further working beyond forged or stamped iron or steel articles. Heading 73.26 / sub-heading 7326.11 was inapplicable because it covers only articles not further worked. Earlier cases cited by the assessee were distinguished on the basis that the goods there were not polished. The classification under Heading 84.82 was therefore upheld.

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Issues: Whether polished steel balls manufactured by the assessee were classifiable under Heading 84.82 of the Central Excise Tariff Schedule or under Heading 73.26 / sub-heading 7326.11.

Analysis: Chapter Note 6 of Chapter 84 applied Heading 84.82 to polished steel balls where the maximum and minimum diameters did not differ from the nominal diameter by more than 1% or 0.05 mm, whichever was less. The test report showed that the goods were polished steel balls satisfying that tolerance. The entry under Heading 73.26 covered only forged or stamped articles of iron or steel not further worked, whereas the goods in question had been further worked by polishing. The earlier decisions relied on by the assessee were distinguished on the ground that the steel balls there were not polished.

Conclusion: The goods were correctly classifiable under Heading 84.82 and not under Heading 73.26 or sub-heading 7326.11. The classification adopted by the adjudicating authority was upheld.

Ratio Decidendi: Polished steel balls satisfying the tolerance prescribed in Chapter Note 6 of Chapter 84 are classifiable under Heading 84.82, and not under the heading meant for forged or stamped iron or steel articles not further worked.

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