Sensitised paper classification turns on essential character after chemical treatment, not later processing or discard of the support layer.

Carbon-tissue paper treated with potassium dichromate and dried became sensitive to light and was used for photogravure work, bringing it within the tariff description of sensitised paper. The relevant classification turned on the product's essential character at the stage of assessment, and the broader allied nomenclature for photographic goods supported inclusion of papers and other light-sensitive materials used for photo-mechanical engraving. The fact that the paper later served as a support and was discarded after exposure and development did not alter its character for tariff purposes. On that basis, the product was treated as sensitised paper under Central Excise Tariff Item No. 37C(2).

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Issues: Whether carbon-tissue paper treated with dichromate solution and dried was correctly classifiable as sensitised paper under Central Excise Tariff Item No. 37C(2).

Analysis: The paper, after treatment with potassium dichromate and drying, became sensitive to light and was used for photogravure purposes. The relevant tariff entry covered sensitised paper, and the scope of the allied nomenclature showed that photographic goods included papers and other materials sensitive to light or other radiations, including those used for photo-mechanical engraving. The fact that the paper functioned as a support and was later discarded after exposure and development did not alter its character at the stage of classification, because the later separation of film and paper was only a subsequent processing step.

Conclusion: The product was correctly treated as sensitised paper under Tariff Item No. 37C(2), and the revision failed.

Ratio Decidendi: A paper product that, after chemical treatment, becomes sensitive to light and answers the description of sensitised paper is classifiable by its essential character at the relevant stage, and later processing or discard of a supporting layer does not change that classification.

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