Abrasive articles on a metal support were classified outside interchangeable tools and under the mineral substances heading.

Diamond impregnated grinding wires bonded to a spring steel wire support were treated as abrasive articles rather than interchangeable tools for customs classification. Because the goods lacked cutting teeth, flutes, grooves or similar features preserving an independent tool identity, they were placed outside Heading 82.05 and within Heading 68.01/16(1) under the mineral substances heading. For countervailing duty purposes, the same ready-to-use goods also fell within Item 51(1) of the Central Excise Tariff Schedule. The note confirms that classification depends on the article's construction and tariff description, not merely its use on a special-purpose machine.

---

---

Issues: (i) Whether diamond impregnated grinding wires were classifiable under Heading 82.05 of the Customs Tariff Act, 1975 or under Heading 68.01/16(1); (ii) Whether the goods were correctly classifiable for countervailing duty purposes under Item No. 51(1) of the Central Excise Tariff Schedule.

Issue (i): Whether diamond impregnated grinding wires were classifiable under Heading 82.05 of the Customs Tariff Act, 1975 or under Heading 68.01/16(1).

Analysis: The goods consisted of fine diamond grains impregnated or bonded on a spring steel wire support. Although used on a special purpose grinding machine, the article did not have cutting teeth, flutes, grooves or the like of base metal retaining identity and function after application of the abrasive, which was necessary to bring it within the scope of Chapter 82. The relevant chapter notes and explanatory notes showed that Heading 82.05 covered tools of a different kind, whereas articles made of abrasive material on a base metal support fell within the mineral substances heading.

Conclusion: The goods were not classifiable under Heading 82.05 and were correctly classifiable under Heading 68.01/16(1), against the assessee.

Issue (ii): Whether the goods were correctly classifiable for countervailing duty purposes under Item No. 51(1) of the Central Excise Tariff Schedule.

Analysis: The goods were fine diamond grains impregnated or bonded on a base of spring steel wire and were made up in ready-to-use form. On the wording of Item No. 51(1), such goods fell within the tariff description applied for central excise purposes.

Conclusion: The goods were correctly classifiable under Item No. 51(1), against the assessee.

Final Conclusion: The appeals failed on both the customs classification dispute and the countervailing duty classification dispute, and the departmental assessments were sustained.

Ratio Decidendi: For customs classification, an article that is merely abrasive material bonded to a base metal support and lacks cutting teeth, flutes or grooves retaining independent tool identity does not fall within the chapter for interchangeable tools, but within the heading for mineral substance articles.

---