Cumulative tariff conditions for sewing thread classification failed where support weight exceeded the statutory limit, defeating exemption denial.

Sewing thread under Note 3 to Section XI requires cumulative satisfaction of all specified conditions, including being put up on supports not exceeding 1000 grams. Because the product was put up on supports exceeding that limit, the statutory definition was not met and the goods could not be classified as sewing thread. The revenue's allegation of weight manipulation was not supported on the record, and the admission-based approach was found inapplicable on these facts. As a result, the adverse classification and demand were set aside and exemption could not be denied on that basis.

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Issues: Whether the product manufactured by the assessee was classifiable as sewing thread for the purposes of the Central Excise Tariff and, consequently, whether the exemption under Notification No. 26/94-C.E. was available.

Analysis: Note 3 to Section XI of the Central Excise Tariff treats sewing thread as multiple or cabled yarn satisfying all the specified conditions, including being put up on supports of a weight not exceeding 1000 grams. The product in question was admittedly put up on supports exceeding 1000 grams, so the condition in clause (a) was not fulfilled. Since all the conditions in the statutory definition must be satisfied cumulatively, failure of any one condition prevents classification as sewing thread. The record also did not support the allegation that the assessee had manipulated the weight to evade duty, and the admission-based reasoning pressed by the Revenue was found inapplicable on the facts.

Conclusion: The product was not sewing thread within the meaning of Note 3 to Section XI and the exemption could not be denied on that basis.

Final Conclusion: The demand and the adverse classification were set aside and the assessee obtained consequential relief.

Ratio Decidendi: Where a tariff definition sets out cumulative conditions for classification, the goods cannot be placed in that entry unless every condition is satisfied, and failure of one essential condition excludes the classification.

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