Tariff classification rectification confirms exemption eligibility under Notification No. 57/2017 for the accepted heading.

An apparent error in recording the competing tariff classifications was corrected by substituting CTH 85176990 for CTH 85176290 in the earlier order. The rectification was based on the mismatch between the recorded text and the rival classifications noted in the proceedings. The order also recorded that, once the goods were classifiable under CTH 85176290, the exemption under Sl. No. 20 of Notification No. 57/2017 dated 30.7.2017 followed on that accepted classification. The appellant was therefore expressly stated to be eligible for the exemption benefit.

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Issues: (i) Whether the last sentence of the earlier order contained an apparent error in recording the competing tariff classification and required rectification; and (ii) whether the appellant was entitled to clarification that exemption under Sl. No. 20 of Notification No. 57/2017 was available on the classification accepted by the Tribunal.

Issue (i): Whether the last sentence of the earlier order contained an apparent error in recording the competing tariff classification and required rectification.

Analysis: The recorded classification in the last sentence of paragraph 2 did not match the competing positions noted in the order. The appellant's classification was CTH 85176290, while the department's classification was CTH 85176990. The incorrect recording was treated as an error apparent on the face of the record and was corrected accordingly.

Conclusion: The classification entry in the last sentence of paragraph 2 was directed to be substituted as CTH 85176990 instead of CTH 85176290.

Issue (ii): Whether the appellant was entitled to clarification that exemption under Sl. No. 20 of Notification No. 57/2017 was available on the classification accepted by the Tribunal.

Analysis: Once the goods were held to fall under CTH 85176290, the exemption consequence followed from the classification already accepted in the earlier order. For clarity, the order expressly recorded that the appellant would be eligible for the exemption benefit under Sl. No. 20 of Notification No. 57/2017 dated 30.7.2017.

Conclusion: The appellant was held eligible for the exemption benefit under Sl. No. 20 of Notification No. 57/2017 dated 30.7.2017.

Final Conclusion: The rectification application succeeded, the mistake in the recorded tariff classification was corrected, and the exemption eligibility of the appellant was expressly affirmed.

Ratio Decidendi: An apparent error in recording a tariff classification can be rectified, and once the goods are held classifiable under the assessee's claimed heading, the corresponding exemption consequence must follow where the notification is applicable.

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