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Issues: Whether rockwool/slagwool and products thereof containing more than 25% by weight of red mud, press mud or blast furnace slag were classifiable under Heading 6803 or under Heading 6807 of the Central Excise Tariff.
Analysis: The goods in dispute were admitted to contain more than 25% by weight of blast furnace slag. The tariff scheme showed that Heading 6803 covered slagwool, rockwool and similar mineral wools in general, while Heading 6807 was specifically enacted for goods in which more than 25% by weight of red mud, press mud or blast furnace slag had been used. The earlier exemption notifications and the Budget changes of 1997 indicated that such goods were intended to be brought under the specific entry in Heading 6807. A construction that kept all rockwool or slagwool under Heading 6803, even where the prescribed composition was met, would make the specific 6807 entry ineffective.
Conclusion: Goods of the kind in question, being rockwool/slagwool containing more than 25% by weight of blast furnace slag, were classifiable under Heading 6807 and not Heading 6803. The reference was answered in favour of the assessee, and the appeals were dismissed.