Quicklime tariff classification under Heading 2522 1000 confirmed for calcined product with CaO below 98% purity.

Imported quicklime that was only calcined and had CaO content of about 92% to 97% was held classifiable under Heading 2522 1000, because the tariff scheme and HSN guidance treat that heading as covering quicklime, while Heading 2825 9090 is reserved for purified calcium oxide of about 98% purity. Applying the relevant chapter notes and an earlier decision on identical facts, the contrary classification adopted by the Revenue was rejected and the impugned classification was set aside.

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Issues: Whether imported quicklime, with CaO content below 98% and subjected only to calcination, was classifiable under Heading 2522 1000 or under Heading 2825 9090.

Analysis: The dispute turned on the correct tariff entry for the imported product. The material facts were not in dispute: the CaO content remained in the range of 92% to 97%, and the only process undertaken was calcination. The applicable classification principles, read with the relevant chapter notes and HSN guidance, show that quicklime is covered under Heading 2522, while Heading 28.25 applies to purified calcium oxide of about 98% purity. The earlier decision on identical facts was applied, and the contrary view relied upon by the Revenue was distinguished.

Conclusion: The goods were correctly classifiable under Heading 2522 1000 and not under Heading 2825 9090.

Final Conclusion: The impugned classification was set aside and the appellant succeeded on the tariff classification dispute.

Ratio Decidendi: Quicklime that is only calcined and has CaO purity below 98% remains classifiable under Heading 2522, and does not fall under Heading 2825 reserved for purified calcium oxide.

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