Customs classification of vulcanized rubber mats turns on specific tariff heading 4016, not unvulcanised rubber heading 4005.

Vulcanized rubber goods cut to shape and identifiable as ready-to-use mats fall under heading 4016 as articles of vulcanized rubber, not under heading 4005, which is confined to unvulcanised compounded rubber in primary forms. The classification was supported by the test report and Rubber Board opinion, and Chapter Note 9 excluded cut-to-shape or further worked goods from the narrower heading. Rule 3(a) favoured the more specific tariff description, and the earlier DEPB-based decision was not determinative for customs classification. The Revenue's classification was sustained.

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Issues: Whether the exported goods, described as rubber mats or rubber compounded sheets, were classifiable under heading 4005 as unvulcanised compounded rubber or under heading 4016 as other articles of vulcanized rubber, and whether the tariff entry and interpretative rule supported the Revenue's classification.

Analysis: The goods were found on the evidence, including the test report and Rubber Board opinion, to be vulcanized and cut to definite size with even edges, grooves, and ready-to-use characteristics. Heading 4005 covers only unvulcanised compounded rubber in primary forms or in plates, sheets or strips, and Chapter Note 9 excludes articles cut to shape or further worked from the scope of the relevant headings. Heading 4016 specifically covers other articles of vulcanized rubber, including mats, and Rule 3(a) of the General Rules for the Interpretation of Import Tariff supports preference for the most specific description. The earlier reliance on the High Court decision concerning DEPB eligibility did not govern customs classification.

Conclusion: The goods were not classifiable under heading 4005 and were correctly classifiable under heading 4016, with the Revenue's view sustained.

Final Conclusion: The appeals were allowed and the classification adopted by the original authority was upheld.

Ratio Decidendi: For customs classification, vulcanized rubber goods cut to shape and identifiable as mats fall under the specific tariff entry for articles of vulcanized rubber and not under the entry confined to unvulcanised compounded rubber.

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