Tariff-heading based classification brings PVC rigid films within Schedule Entry C-54 and supports tax treatment under the notification.

PVC rigid plain, coated and laminated films were found to fall within Schedule Entry C-54 because the notified entry covers industrial inputs and packing materials identified by reference to Heading 3920 of the Central Excise Tariff Act, 1985. On the material before the Authority, the goods answered the tariff description for plastics film under CETH 3920 49 00, so they were treated as covered by the notification and the schedule entry. The products were therefore held to be taxable under Schedule Entry C-54 in favour of the assessee.

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Issues: Whether PVC rigid plain film, PVC rigid coated film, and PVC rigid laminated film are covered by Schedule Entry C-54 as industrial inputs and packing materials.

Analysis: Schedule Entry C-54 applies to industrial inputs and packing materials as notified by the State Government. The notification issued for that entry specifies goods falling under Heading 3920 of the Central Excise Tariff Act, 1985, including plates, sheets, film, foil and strip of plastics. The products in question are PVC rigid films made of polymers of vinyl chloride and, on the material placed before the Authority, correspond to CETH 3920 49 00. Since the notified tariff description covers the goods, the products fall within the scope of the notification and the schedule entry.

Conclusion: The products are covered by Schedule Entry C-54 and are liable to tax accordingly in favour of the assessee.

Ratio Decidendi: Where a notified schedule entry incorporates goods identified by reference to a tariff heading, a product that answers the notified tariff description falls within the entry and is covered by the notification.

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