Tariff classification of coated woven fabric turns on plastic coating requirement, not end use, and Revenue's claim failed.

For classification under Heading 5903, the primary statutory requirement is that the textile fabric be impregnated, coated, covered or laminated with plastics; visibility of the coating to the naked eye becomes relevant only after that threshold is met. The test reports showed a visible aluminium paste or silver coating, but not coating with plastics, so Heading 5903 was not established. The evidence also did not prove the additional requirements for Heading 54071094, including that the fabric was made from high tenacity yarn. End use as umbrella cloth could not determine tariff classification, and the Revenue's appeal was rejected.

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Issues: Whether the imported woven fabric was correctly classifiable under Heading 5903 of the Customs Tariff Act or under Heading 54071094 as claimed by Revenue.

Analysis: The test reports showed that the goods were coated and that the coating was visible to the naked eye, but they also indicated that the coating was aluminium paste or silver coating and not coating with plastics. For Heading 5903, Chapter Note 2(a) requires textile fabrics impregnated, coated, covered or laminated with plastics, and the visibility test operates only after that primary requirement is met. The evidence also did not establish the further parameters necessary for classification under Heading 5407, including whether the fabric was made from high tenacity yarn. End use as umbrella cloth was held not to be the test for classification, and classification had to depend on the nature of the material and coating.

Conclusion: The goods were not classifiable under Heading 54071094 as proposed by Revenue, and the Revenue's appeal failed.

Final Conclusion: The classification adopted by the lower authority was not sustained on the material relied upon by the Revenue, and the appeal was rejected.

Ratio Decidendi: For classification under Heading 5903, coating with plastics is the primary statutory requirement, and visibility of coating to the naked eye becomes relevant only after that requirement is satisfied; end use alone cannot determine tariff classification.

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