Pre-deposit relief in sticker classification dispute granted on reduced payment pending appeal

In a classification dispute over self-adhesive stickers, the tribunal noted that the goods were prima facie capable of being treated as labels or printed goods under the tariff notes relied on by the assessee, while the revenue argued for Chapter 48 classification. As the issue required close examination of tariff descriptions and HSN notes, complete waiver of pre-deposit was declined. The appellant was instead granted interim relief on a reduced pre-deposit, with the balance waived and recovery stayed during the appeal upon compliance.

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Issues: Whether the appellant was entitled to waiver of the balance pre-deposit and stay of recovery pending appeal in a classification dispute concerning self-adhesive stickers.

Analysis: The disputed stickers were prima facie viewed as labels or printed goods falling within the tariff notes relied upon by the appellant, while the revenue relied on Chapter 48 classification. The dispute required detailed examination of tariff descriptions and HSN notes, and the original authority had accepted the appellant's view at the initial stage. In these circumstances, complete waiver was not considered appropriate, but the appellant was granted substantial interim relief on payment of a reduced amount.

Conclusion: The appellant was directed to make a pre-deposit of Rs. 50,000, and on compliance the balance pre-deposit was waived with stay of recovery during the pendency of the appeal.

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