Tariff classification of wood products turns on whether gluing and lamination create distinct articles of wood or remain heading 4403 goods.

Mere processing of wood by edge-gluing, jointing or lamination does not, by itself, remove goods from heading 4403 unless they have become distinct articles of wood as end products. On examination of the manufacturing process and tariff descriptions, the goods retained their character as wood products and were therefore classifiable under heading 4403 rather than heading 4410.

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Issues: Whether Finger Jointed Edge Glued Panels and Laminated Square Beams are classifiable under heading 4403 of the Central Excise Tariff Act, 1985 or under heading 4410 as articles of wood.

Analysis: The dispute turned on the proper tariff classification of the goods. The Revenue relied on the HSN notes to contend that processes such as edge-gluing and lamination took the goods out of heading 4403, while the assessee maintained that such processes did not alter the essential character of the wood so as to make it an article of wood. The goods were examined along with the manufacturing process, and the lower authorities had found that the HSN explanatory notes did not exclude wood subjected to gluing, whether edge-wise or face-wise, from heading 4403. The view was also taken that an article of wood is an end product, whereas the goods in question remained wood products falling within the tariff description of heading 4403.

Conclusion: The goods were correctly classifiable under heading 4403 and not under heading 4410.

Ratio Decidendi: Mere processing of wood by gluing, edge-jointing or lamination does not, by itself, take the product out of heading 4403 unless the goods have become distinct articles of wood as end products.

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