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Issues: Whether playing cards, classifiable under Chapter 95, were entitled to the concessional rate of duty as "sports goods" under Notification No. 02/2011-CE dated 01.03.2011.
Analysis: The notification granted concessional duty to sports goods falling under Chapter 95, without carving out a separate exclusion for playing cards. The goods in question were admittedly classifiable under Chapter 95. A prior Tribunal decision on identical facts had held that the expression "sports goods" is of wide import and includes playing cards, and that decision had been followed subsequently. The distinction sought to be drawn from another case was not accepted because that matter did not concern playing cards and was not directly on point. On the plain wording of the notification and the binding value of the directly applicable precedent, the concession could not be denied.
Conclusion: Playing cards were held eligible for the concessional rate as sports goods under the notification, and the demand was set aside in favour of the assessee.
Ratio Decidendi: Where a notification grants concessional duty to sports goods falling under a specified chapter, goods admittedly falling within that chapter are covered if the notification's language, read plainly and in the light of directly applicable precedent, does not exclude them.
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