Tariff classification of diamond products follows the entry in force at the relevant time, with broad coverage of grinding wheel parts.

Tariff classification turned on the wording of Item 51 of the Central Excise Tariff Schedule as it stood during the relevant period. Diamond products were treated as covered by that entry because it was wide enough to include complete grinding wheels as well as segments and other finished parts, and the goods performed the same basic grinding function. The later introduction of Item 51A for tools did not govern an earlier period when that entry did not exist. Reliance on Indian Standard specifications and a later trade notice did not displace the applicable tariff description, so the classification under Item 51 was upheld.

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Issues: Whether the assessee's diamond products were correctly classified under Item 51 of the Central Excise Tariff Schedule as grinding wheels and the like, or whether they fell outside that entry and were properly classifiable as tools only after the later introduction of Item 51A.

Analysis: The tariff entry in force during the relevant period was considered wide enough to include not only complete grinding wheels but also segments and other finished parts of such wheels. The fact that some goods were not in the form of complete wheels did not take them outside Item 51. The later introduction of Item 51A for tools did not control the classification for an earlier period when that item did not exist. The goods performed the same basic function as grinding tools, and the Chapter-note reasoning under the CCCN showed that overlapping between tools and grinding-wheel type goods was possible. The reliance placed on Indian Standard specifications and a later trade notice did not displace the tariff description applicable at the material time.

Conclusion: The goods were rightly held to be covered by Item 51, and the classification adopted by the lower authorities was upheld.

Ratio Decidendi: For tariff classification, the goods must be tested against the entry as it stood during the relevant period, and a broad entry covering grinding wheels and their finished parts can include diamond products performing that function even if they are not complete wheels; a later, more specific entry does not govern an earlier period.

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