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Issues: Whether iron or steel coils imported for re-rolling were classifiable under Entry 73.08 of the Customs Tariff Act or under Entry 73.13 of the Customs Tariff Act.
Analysis: The import was shown to be of coils for re-rolling, and that factual assertion was not disputed. The tariff notes in Chapter 73 indicated that coils for re-rolling were semi-finished hot rolled products, and note (k) showed that such iron or steel coils, whether hot rolled or cold rolled, fell within Entry 73.08. On that basis, the Department's reliance on Entry 73.13 for sheets and plates could not be sustained.
Conclusion: The goods were held classifiable under Entry 73.08 and not under Entry 73.13, and the assessment under Entry 73.13 was set aside in favour of the petitioner.
Ratio Decidendi: Where imported iron or steel coils are meant for re-rolling, the specific tariff entry covering coils for re-rolling governs classification rather than the general entry for sheets and plates.