Tariff classification of grinding machinery depends on whether soda ash qualifies as a mineral substance under the relevant entry.

Tariff classification of machinery for grinding soda ash could not be finally decided without first determining whether soda ash falls within the statutory description of "earth, stone, ores or other mineral substances" under Tariff Item 84.56. The Tribunal had accepted classification under that entry, but the record contained no finding on the nature of soda ash, which was essential to decide whether the goods belonged under Item 84.56 or Item 84.59. The Supreme Court therefore set aside the order and remitted the matter to the Tribunal for fresh disposal in accordance with law.

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Issues: Whether the classification dispute concerning grinding discs could be finally decided without determining whether soda ash answers the description of earth, stone, ores or other mineral substances under Tariff Item 84.56.

Analysis: The Tribunal had accepted classification under Tariff Item 84.56, while the Revenue contended that the goods fell under Tariff Item 84.59. The governing entry under Tariff Item 84.56 applies only if the machinery is for grinding or mixing earth, stone, ores or other mineral substances in solid, including powder or paste, form. The record showed that the goods were meant for grinding soda ash, but there was no finding on whether soda ash falls within the expression mineral substances in the relevant tariff entry. Without that determination, the classification question could not be correctly resolved.

Conclusion: The appeal was allowed, the impugned order was set aside, and the matter was remitted to the Tribunal for fresh disposal in accordance with law.

Final Conclusion: The classification issue remained open for reconsideration by the Tribunal, and the appellate interference resulted in a remand rather than a final determination on merits.

Ratio Decidendi: A tariff classification under an entry covering mineral-processing machinery cannot be sustained unless the adjudicating authority first determines whether the material processed falls within the statutory description of mineral substances.

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