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Issues: Whether the imported bonded fabric was classifiable under the heading declared by the assessee or under the heading proposed by the Revenue.
Analysis: The imported goods were bonded fabric and not general textile goods. The Section Note relied on by the Revenue was held to apply to textiles and textile articles in general and, on the facts, was found inapplicable to the imported fabric. The circular governing bonded fabrics was read as requiring classification to depend on the type of textile material and the nature of bonding. The first appellate authority's approach of applying the General Rules for Interpretation, particularly Rule 3(c), was upheld, and the Revenue's reliance on the predominance test and the cited Delhi decision was found misplaced on the facts.
Conclusion: The goods were correctly classified under the heading declared by the assessee.
Ratio Decidendi: Where bonded fabric is specifically covered by an interpretative circular and the general section note on mixed textile materials is inapplicable on the facts, classification must be determined under the General Rules for Interpretation, including Rule 3(c), rather than by applying the predominance test.