Tariff classification of hollow goods follows chapter notes, with hollow profiles falling under Heading 7304 rather than Chapter 72.

Tariff classification under the Customs Tariff Act turns on the statutory description in the tariff headings and chapter notes, not on the manufacturing process. Hollow imported goods lacking a solid cross-section could not be treated as semi-finished products or other bars and rods under Chapter 72 because Chapter Note 1(ij) confines semi-finished products to solid section products and Note 1(m) applies only to uniform solid cross-sections. Chapter Note 1(p) directs hollow bars and rods not covered by Chapter 72 to Heading 7304, so the goods fall under tubes, pipes and hollow profiles.

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Issues: Whether the imported goods were classifiable as semi-finished products under Heading 7224 of the Customs Tariff Act, 1975 or as tubes, pipes and hollow profiles under Heading 7304 of the Customs Tariff Act, 1975.

Analysis: Chapter Note 1(ij) to Chapter 72 confines semi-finished products to products of solid section, and Chapter Note 1(m) applies only to products having a uniform solid cross-section. The imported goods were found to be hollow and not of solid section, so they could not be classified as semi-finished products or as other bars and rods under Chapter 72. Chapter Note 1(p) specifically provides that hollow bars and rods not conforming to the note are to be classified in Heading 7304. The argument based on the manufacturing process was not accepted because the process of manufacture was held to be irrelevant for classification under Heading 7304.

Conclusion: The goods were correctly classifiable under Heading 7304 and not under Heading 7224.

Final Conclusion: The classification adopted by the lower authorities was sustained and the appeal failed.

Ratio Decidendi: For tariff classification, the governing test is the statutory description in the tariff and chapter notes, and goods lacking a solid cross-section cannot be treated as semi-finished products under Chapter 72; manufacturing process does not control classification where the tariff language is specific.

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