Button classification under Heading 96.06 upheld for functional button components over base-metal fittings.

Brass eyelets, rivet sets, toti buttons, buckles and similar goods were treated as buttons or functional parts of button mechanisms, so classification followed the specific HSN entry for buttons under Heading 96.06 rather than the general base-metal fittings entry under Heading 83.08. The finding that the goods were cleared independently was not displaced by contrary material, and the cited precedent supported the Commissioner (Appeals)' view. On that basis, the Revenue's challenge to the consequential relief could not succeed and the classification under Heading 96.06 was upheld.

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Issues: Whether brass eyelets, rivet sets, toti buttons, buckles and similar items were correctly classifiable as buttons under Heading 96.06 or under Heading 83.08, and whether the Revenue appeal against the consequential relief could succeed.

Analysis: The impugned order had found that the disputed items were buttons or functional parts of button mechanisms and that they were cleared independently. No material was shown to dislodge that finding. The competing headings were examined with reference to the HSN notes, and Heading 96.06 was treated as the appropriate entry. The reasoning also accepted that the classification adopted by the Commissioner (Appeals) was supported by the cited precedent and that nothing contrary was produced to disturb that view.

Conclusion: The goods were held classifiable under Heading 96.06 and not under Heading 83.08. The Revenue appeal failed.

Ratio Decidendi: Where goods are functionally buttons or button components and fall within the relevant HSN description, classification must follow the specific heading applicable to buttons rather than the general heading for base-metal fittings.

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