Tariff classification of tyre cord warp sheets depends on the statutory description, not predominance of material alone.

Classification of tyre cord warp sheets dipped in Resorcinol Formal Dehyde Latex Solution turned on whether they answered the specific description of "man-made fabric" under Tariff Item 22. The Court noted that the entry covered only fabrics impregnated, coated or laminated with cellulose derivatives or other artificial plastic materials, or fabrics covered with textile flocks, and the goods were not shown to fall within that language. It rejected reliance on a predominance test alone and held that prior authority had to be read in context. Tariff Item 22 was not attracted on the material before the Court, and the matter was remitted for fresh consideration.

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Issues: Whether tyre cord warp sheets dipped in Resorcinol Formal Dehyde Latex Solution were classifiable under Tariff Item 22(1)(b) of the Central Excise Tariff or under Entry 16A(2) of the erstwhile Central Excise tariff.

Analysis: The expression "man-made fabric" in Tariff Item 22 was held to cover only the specific categories described in that entry, namely fabrics impregnated, coated or laminated with preparations of cellulose derivatives or other artificial plastic materials and fabrics covered with textile flocks. The goods in question were not shown to answer that description. The Tribunal's approach, which relied substantially on the predominance test and on the earlier decision in Fenoplast, was held to be unsatisfactory because that decision had to be understood in its proper context and not as a complete answer to the classification dispute.

Conclusion: Tariff Item 22 was not held to be attracted on the material before the Court, and the Tribunal's order was set aside with the matter remitted for fresh consideration in accordance with law.

Ratio Decidendi: Where a tariff entry is limited to specifically described goods, classification cannot be sustained merely by invoking predominance of material without first establishing that the goods answer the statutory description of the entry.

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