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Issues: Whether imported granola bars were classifiable under Heading 1905 9090 of the First Schedule to the Customs Tariff Act, 1975 as claimed by the importer, or under Heading 1904 9000 as adopted by the assessing authority and upheld in appeal.
Analysis: The imported goods were found to be a baked mixture of oats and several other ingredients, with the oats only forming part of the finished product known as granola bars. The classification exercise was guided by the Harmonized System Explanatory Notes, under which Heading 1904 covers prepared cereals and cereal preparations, including pre-cooked or otherwise prepared cereals, but the product here underwent mixing and baking that altered its character as a cereal preparation. The lower authorities had also proceeded by rejecting the importer's claim rather than demonstrating why the proposed classification was the more apt one.
Conclusion: The goods were not correctly classifiable under Heading 1904 9000, and the importer's claimed classification under Heading 1905 9090 was accepted.