Customs classification must consider every relevant tariff entry; missing entries require remand for fresh determination.

Correct customs classification of imported semi-finished forgings for connecting rods required examination of all potentially applicable tariff entries, including Entry 87.09/12 as well as Entries 76.08/16 and 84.06. Because Entry 87.09/12 had not been canvassed by the department or considered by the Tribunal, the classification dispute could not be finally resolved on the existing record. The Supreme Court set aside the Tribunal's order and remitted the matter for fresh determination in accordance with the Customs Tariff Act, 1975, with the parties to be given opportunity to adduce evidence and make submissions.

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Issues: Whether the imported semi-finished forgings for connecting rods were classifiable under Entry 76.08/16 or Entry 84.06, and whether Entry 87.09/12 also required consideration for correct customs classification.

Analysis: The classification dispute could not be finally resolved on the material before the Tribunal because one possible entry, namely Entry 87.09/12, had not been canvassed by the department before the Tribunal and had not been considered there. Correct classification required examination of all relevant and appropriate entries under the Customs Tariff Act, 1975, together with the rules for interpretation of the Schedule, and the parties were to be given opportunity to adduce evidence and make submissions before the Tribunal.

Conclusion: The order of the Tribunal was set aside and the matter was remanded for fresh decision on classification in accordance with law.

Ratio Decidendi: For correct tariff classification, all relevant entries must be considered, and where a potentially applicable entry has not been examined, the matter should be remitted for a fresh determination.

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