Tariff classification cannot be narrowed by trade usage, and writ relief remains available despite a revisional remedy.

Tariff classification must be governed by the entry itself, and trade usage or administrative practice cannot add restrictions not found in the statute or tariff description. On that basis, the note states that imported newsprint could not be denied concessional assessment merely because it was not shown to be intended exclusively for newspaper printing or to satisfy a minimum reel width not fixed by the tariff, and the refusal of refund was unsustainable. It further notes that the explained delay, the filing of certiorari petitions, and the presence of a revisional remedy did not bar writ interference, because the alternative remedy was not treated as adequate to exclude relief.

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Issues: (i) whether trade usage or administrative practice could be read into the tariff description so as to deny assessment at the concessional rate and refuse refund of excess customs duty; (ii) whether delay, the form of writ sought, or the availability of a revisional remedy barred interference under writ jurisdiction.

Issue (i): whether trade usage or administrative practice could be read into the tariff description so as to deny assessment at the concessional rate and refuse refund of excess customs duty.

Analysis: The tariff description was treated as controlling. No statutory rule required the imported newsprint to be intended exclusively for newspaper printing, and no statutory condition fixed a minimum width for classification as newsprint in reels. Administrative practice and trade usage could not be imported to add limitations not found in the tariff entry itself.

Conclusion: The higher assessment could not be sustained, and the refusal of refund was against the petitioner.

Issue (ii): whether delay, the form of writ sought, or the availability of a revisional remedy barred interference under writ jurisdiction.

Analysis: The delay was explained by the pendency of an earlier writ concerning the same issue, and the explanation was accepted. The objection as to the form of relief was neutralised by the filing of writ petitions seeking certiorari. The existence of a revisional remedy was held not to be an adequate alternative remedy so as to preclude writ relief.

Conclusion: These objections did not bar relief, and writ interference was held to be maintainable.

Final Conclusion: The challenge to the refund refusals succeeded on the merits, while the technical objections to writ relief were rejected; the result was that the petitions seeking certiorari were allowed and the mandamus petitions were dismissed.

Ratio Decidendi: A tariff description cannot be narrowed by trade usage or executive practice unless such limitation is found in the statute or tariff entry itself, and a revisional remedy does not automatically bar writ relief where the claim is otherwise fit for judicial interference.

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