Tariff classification follows actual chemical composition, and invoice descriptions cannot override the true nature of the goods.

Tariff classification of repacked goods depended on their actual chemical composition and the record evidence already available from the principal, including the show cause notice and order-in-original. In a second round of litigation, further chemical testing was treated as unnecessary and remand was found to serve no useful purpose. The documented analysis supported classification under Heading 3403, and a different sub-heading shown in invoices could not override the true nature of the goods. The classification under Heading 3403 was upheld and the challenge failed.

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Issues: Whether the goods re-packed by the job worker were correctly classifiable under Heading 3403 of the Central Excise Tariff Act, 1985 instead of Sub-heading 2710.90.

Analysis: The chemical composition furnished by the principal was already available on record and had been discussed in the show cause notice and the order-in-original. In a second round of litigation, further chemical testing was found unnecessary, and no useful purpose would be served by remanding the matter. On merits, the documented chemical analysis and the materials submitted by the principal supported classification under Heading 3403, and the mere mention of a different sub-heading in invoices could not override the actual nature of the goods.

Conclusion: The classification under Heading 3403 was upheld and the appellant's challenge failed.

Final Conclusion: The appeal was rejected after affirming the department's tariff classification of the goods.

Ratio Decidendi: Tariff classification must follow the actual chemical composition and record evidence, and not a mistaken invoice description, particularly where the principal's analysis already supports the assessed heading.

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