Chapter 26 classification turns on actual processing and resulting character of iron oxide powder, requiring fresh examination.

Classification of exported iron oxide powder depended on whether the goods remained covered by Chapter 26 or had moved to Chapter 28 after processing. The relevant Chapter 26 note excludes minerals subjected to processes not normal to the metallurgical industry, so the decisive inquiry was the actual processing undertaken and its effect on the goods' character and end-use. The lower authorities erred by applying a general manufacturing-process approach without examining the record, including the processing flow chart and the claimed suitability for oilfield chemicals. The matter was remanded for fresh consideration on that basis.

---

---

Issues: Whether the exported product, described as iron oxide powder, was correctly classifiable as iron ore under Chapter 26 or as a product under Chapter 28; and whether the material question was whether the processes shown by the assessee took the goods outside the scope of ores under Chapter 26.

Analysis: The relevant Chapter 26 note excludes minerals that have been subjected to processes not normal to the metallurgical industry. The record contained a flow chart showing multiple processing stages and the assessee's case was that, after such processing, the goods became fit for use in oilfield chemicals rather than for metallurgical extraction. The lower authorities treated the matter as if a manufacturing-process test were required and did not examine the actual processes shown on record or their effect on the character and end-use of the goods.

Conclusion: The classification issue required reconsideration on the basis of the processes actually undertaken and their outcome; the matter was remanded to the Commissioner (Appeals) for fresh consideration.

Ratio Decidendi: For goods falling within Chapter 26, the decisive inquiry is whether they have undergone processes not normal to the metallurgical industry, and classification cannot be sustained without examining the actual processing and resultant character of the goods.

---