Tariff classification of laminated goods turned on jute predominance, so the jute-manufacture entry prevailed over the paper-based entry.

Laminated goods made of paper and hessian bonded with bitumen were held classifiable under Item 22A as jute manufactures because jute predominated in weight. Item 17(2) for paper and paper-board, including goods subjected to coating or impregnation, did not reasonably extend to a product formed by laminating paper with jute where a substantial part of the weight was non-paper material. The express wording of Item 22A, covering jute manufactures where jute predominated, prevailed over the broader paper-based description in Item 17(2). The contrary duty demand was set aside and the assessee's classification was accepted.

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Issues: Whether laminated goods consisting of paper and hessian bonded with bitumen, in which jute predominated in weight, were classifiable under Item 22A of the Central Excise Tariff Schedule as jute manufactures or under Item 17(2) as paper and paper-board.

Analysis: The goods were found to contain jute as the predominant material by weight. Item 22A covered jute manufactures of all sorts not elsewhere specified in which jute predominated in weight, and the description fit the goods squarely. Item 17(2), which covered paper and paper-board including articles subjected to processes such as coating or impregnation, could not reasonably extend to a product produced by laminating paper with jute, especially where a substantial part of the weight was made up of non-paper material. The absence of an express enlargement in Item 17 comparable to the wording of Item 22A also weighed against classifying the goods under Item 17(2).

Conclusion: The goods were classifiable under Item 22A and not under Item 17(2), and the classification urged by the assessee was accepted.

Final Conclusion: The demand based on the contrary classification could not stand for the relevant period, and the appeal succeeded with the duty demand set aside.

Ratio Decidendi: Where a tariff entry expressly covers goods in which a stated material predominates in weight, that entry prevails over a broader paper-based description that does not specifically embrace laminated goods containing substantial non-paper material.

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