Coal classification needs literature-backed scientific parameters before customs duty treatment can be finally determined.

Imported coal classification under the customs tariff turned on whether the goods were coking coal or other coal, but the record did not identify literature-backed benchmarks or scientific parameters for that distinction. The notification prescribed different duties, yet the material before the authorities did not disclose the specific moisture, ash, volatile matter, or CSN thresholds used to support the classification. In the absence of a scientifically supported basis, the dispute could not be finally determined on the existing record. The order was therefore set aside and the matter remitted for fresh adjudication after identifying and applying proper literature-supported parameters.

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Issues: Whether the imported coal was correctly classifiable as coking coal or as goods other than coking coal, and whether the dispute could be finally decided without identifiable parameters supported by literature.

Analysis: The notification in force prescribed different customs duties for coking coal and for goods other than coking coal, but at the material time it did not define coking coal. The records and laboratory reports only recorded test parameters and conclusions, but did not disclose the specific parameters or benchmark literature used to distinguish coking coal from other coal. The adjudicating and appellate orders also did not furnish a scientific basis showing the moisture, ash, volatile matter, or CSN thresholds that would determine the classification. In these circumstances, final determination of the classification issue was not possible on the material then available.

Conclusion: The classification issue could not be finally upheld or rejected on the existing record and required reconsideration by the original adjudicating authority after identifying and relying upon specific literature-supported parameters.

Final Conclusion: The impugned order was set aside and the matter was sent back for fresh adjudication on the classification of the imported coal.

Ratio Decidendi: Where the tariff description is not scientifically benchmarked in the record and the department does not establish literature-backed parameters for distinguishing one mineral variety from another, the classification dispute cannot be finally adjudicated and must be reconsidered on a proper evidentiary basis.

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