HSN-based customs classification places artificial graphite tubes under Chapter 68, excluding them from Chapter 84 machinery parts.

Karbate tubes made of artificial graphite impregnated with phenolic resin, used as heat exchanger parts, are classifiable under sub-heading 6815.10 because the HSN-aligned Customs Tariff expressly covers non-electrical articles of natural or artificial graphite, including tubes and sheaths. Chapter Note 1(a) to Chapter 84 excludes articles falling under Chapter 68 from Chapter 84 even when they serve as machinery parts, so Heading 84.19 does not apply. Earlier pre-HSN and Central Excise rulings were not determinative against the tariff scheme and HSN Explanatory Notes applicable to customs classification.

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Issues: Classification of karbate tubes made of artificial graphite impregnated with phenolic resin, used as parts of heat exchangers, under Chapter Heading 6815.10 or Chapter Heading 84.19 of the Customs Tariff Act, 1975.

Analysis: The imported goods were non-electrical articles of artificial graphite. The Customs Tariff, as amended, was aligned with the Harmonised System of Nomenclature, and the HSN Explanatory Notes under Heading 68.15 specifically covered non-electrical articles of natural or artificial graphite, including tubes and sheaths. The tariff entry did not restrict the heading to natural graphite only. In view of Chapter Note 1(a) to Chapter 84, articles falling under Chapter 68 stood excluded from Chapter 84 even if they were parts of machinery. The relied-upon earlier decisions under the pre-HSN regime or under the Central Excise Tariff did not displace the HSN-based classification applicable to the Customs Tariff.

Conclusion: The goods were correctly classifiable under sub-heading 6815.10 and not under Chapter Heading 84.19.

Ratio Decidendi: Where the Customs Tariff is aligned to the HSN and the HSN Explanatory Notes expressly include artificial graphite articles within Heading 68.15, such goods are classified under Chapter 68 and are excluded from Chapter 84 by Chapter Note 1(a), even if they are parts of machinery.

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