Tariff classification of aluminium-coated paper favoured Heading 4810 because the product contained no plastic material.

Paper coated on one side with aluminium metal powder, and free from plastic material, was held to fall under Heading 4810 rather than Heading 4811. Heading 4811 applies only to paper and paperboard coated, impregnated or covered with plastics, whereas Heading 4810 covers paper and paperboard coated with inorganic substances. Since the test report established absence of plastic and the product matched the description of coated paper under the specific heading, the Revenue's classification could not be sustained and the assessee's classification claim succeeded.

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Issues: Whether the assessee's aluminium-coated paper was classifiable under Heading 4810 as paper and paperboard coated with inorganic substances, or under Heading 4811 as paper and paperboard coated, impregnated or covered with plastics.

Analysis: The dispute turned on the composition of the product and the scope of the competing tariff entries. The product was found to be paper coated on one side with aluminium metal powder and free from plastic material. Heading 4811 applies only to paper and paperboard coated, impregnated or covered with plastics, while Heading 4810 covers paper and paperboard coated on one or both sides with kaolin or other inorganic substances. Since the test report established absence of plastic and the product answered the description of coated paper under Heading 4810, the Revenue's classification under Heading 4811 could not be sustained.

Conclusion: The classification adopted by the lower authorities was incorrect, and the goods were not classifiable under Heading 4811; the assessee's claim succeeded.

Final Conclusion: The duty demand based on classification under Heading 4811 failed, and the assessee obtained relief on classification.

Ratio Decidendi: Where a product answers the description of a specific tariff entry and the competing entry requires a material ingredient absent from the goods, classification must follow the specific entry and the Revenue cannot sustain the broader competing heading.

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