Visible thermoplastic coating and heat-bonding capacity place fusible interlining fabrics under Heading 5903, not Chapter 52.

Fusible interlining fabrics of cotton with a thermoplastic coating visible to the naked eye were held classifiable under Heading 5903, not Chapter 52. Chapter Note 2(a) to Chapter 59 was applied to exclude only fabrics where the coating is not visible to the naked eye or where partial coating produces designs; the sample goods did not fall within that exclusion. Their ability to bond other fabrics on application of heat and pressure also aligned with the explanatory notes to Heading 5903. Arguments based on deletion of the earlier note and prior circulars were rejected because they could not override the tariff text and explanatory notes.

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Issues: Whether fusible interlining fabrics of cotton, having dot-printed thermoplastic coating visible to the naked eye, are classifiable under Heading 5903 or under Chapter 52.

Analysis: Chapter Note 2(a) to Chapter 59 excludes only those fabrics in which the coating cannot be seen with the naked eye or which are partially coated or partially covered with plastics and bearing designs resulting from such treatment. On the sample reports and physical examination, the coating was visible to the naked eye and the goods were printed in a set pattern on one side. The fabrics were also capable of providing a bond to other fabrics on application of heat and pressure, which is specifically covered by the explanatory notes to Heading 5903. The alternative contention based on deletion of the erstwhile Chapter Note 2(c) and earlier circulars was not accepted as overriding the tariff text and explanatory notes.

Conclusion: The goods are classifiable under Heading 5903 and not under Chapter 52.

Final Conclusion: The classification dispute was decided in favour of the revenue position, confirming GST classification under Heading 5903 for fusible interlining fabrics of cotton.

Ratio Decidendi: Where textile fabric has a visible thermoplastic coating and is capable of bonding other fabrics on application of heat and pressure, it falls within Heading 5903 unless it squarely satisfies a specific exclusion in Chapter Note 2(a) to Chapter 59.

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