Tariff classification of quicklime turns on specific heading coverage and purity threshold under the competing HSN-based entry.

Quicklime with CaO content below 98% was held classifiable under Heading 25.22 because that entry specifically covers quicklime, while Heading 28.25 applies to calcium oxide or hydroxide in the pure state. The HSN explanatory notes support Heading 28.25 only for calcium oxide of high purity, about 98% or more, and expressly exclude quicklime. As the imported goods did not meet that purity standard, the Revenue's reclassification under Heading 28.25 could not prevail over the specific tariff description. The differential customs duty demand based on reclassification was therefore not sustainable.

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Issues: Whether the imported product, quicklime with CaO content below 98%, was classifiable under Heading 25.22 or Heading 28.25 of the Customs Tariff.

Analysis: Heading 25.22 expressly covers quicklime, slaked lime and hydraulic lime, while Heading 28.25 covers calcium oxide and hydroxide in the pure state. The HSN explanatory notes to Heading 28.25 exclude quicklime and indicate that the heading applies to calcium oxide of high purity, approximately 98% or more. The goods in question were found to have purity below that level, and the classification adopted by Revenue could not override the specific coverage of quicklime under Heading 25.22. The relied-upon earlier authorities did not displace the applicable HSN-based classification on the facts of this case.

Conclusion: The product was rightly classifiable under Heading 25.22 and not under Heading 28.25.

Final Conclusion: The differential customs duty demand based on reclassification could not be sustained, and the appeal succeeded.

Ratio Decidendi: Where a tariff entry specifically names quicklime and the imported goods do not satisfy the purity standard associated with calcium oxide under the competing entry, classification must follow the specific heading as clarified by the HSN explanatory notes.

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