Customs exemption for platinum-rhodium wire: tariff classification and notification wording can preserve duty relief despite alloy composition.

Imported platinum wire and platinum-rhodium wire were treated as classifiable under Heading 7110, and the notification entry covering platinum under that heading was held to match the tariff description; the presence of rhodium did not alter the essential classification, so concessional basic customs duty under Notification No. 12/2012-CUS was available. The same goods were also regarded as falling within the notification covering platinum and allied precious metals in primary, unfinished or semi-finished forms, including wires, so nil additional duty under Notification No. 12/2012-CE was available. As the goods fell within Chapter 71 and no exclusion applied, exemption from special additional duty under Notification No. 21/2012-CUS was also available.

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Issues: (i) Whether imported platinum wire and platinum-rhodium wire were eligible for concessional basic customs duty under Notification No. 12/2012-CUS; (ii) Whether the same goods were entitled to nil additional duty of customs under Notification No. 12/2012-CE; (iii) Whether the goods qualified for exemption from special additional duty under Notification No. 21/2012-CUS.

Issue (i): Whether imported platinum wire and platinum-rhodium wire were eligible for concessional basic customs duty under Notification No. 12/2012-CUS.

Analysis: The goods were classified under Heading 71101900 and the notification entry covered platinum under Heading 7110 11 or 7110 19 00. The description in the notification matched the tariff classification of the imported goods, and the presence of rhodium did not alter the essential classification where the chapter note treated platinum to include platinum-rhodium material.

Conclusion: The exemption under Notification No. 12/2012-CUS was available.

Issue (ii): Whether the same goods were entitled to nil additional duty of customs under Notification No. 12/2012-CE.

Analysis: The relevant entry covered platinum and allied precious metals in their primary forms, including unfinished or semi-finished forms such as rods, sheets, foils and wires. Platinum-rhodium wires fall within that description, and the notification was construed as borrowing the language of Heading 71.10 itself, so the alloy composition did not justify denial of the benefit.

Conclusion: The exemption under Notification No. 12/2012-CE was available.

Issue (iii): Whether the goods qualified for exemption from special additional duty under Notification No. 21/2012-CUS.

Analysis: The entry granted exemption to all goods falling under Chapter 71, except articles of jewellery and goods excluded by the notification. The imported goods fell within Chapter 71 and were not covered by any exclusion, so the benefit could not be denied.

Conclusion: The exemption under Notification No. 21/2012-CUS was available.

Final Conclusion: The denial of exemption benefits was unsustainable, the assessee's appeal succeeded, and the Revenue's appeal failed.

Ratio Decidendi: Where imported goods are classifiable under the tariff heading covered by an exemption notification, a minor compositional element such as rhodium does not defeat the exemption if the tariff description and the notification entry correspond and no exclusion applies.

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