Tariff classification of inks turns on HSN notes, separating writing and drawing inks from specialised marker and hi-liter inks.

Tariff classification under heading 3215 turned on the scope of the heading read with the HSN notes. Drawing inks were treated as falling within the wider concept of writing inks and therefore classifiable under sub-heading 3215.10. Marker inks and hi-liter inks were treated as specialised inks distinct from ordinary writing inks and therefore classifiable under sub-heading 3215.90 as other inks. The classification exercise thus separated ordinary writing and drawing inks from specialised marker and hi-liter inks, and the matter was remitted for recomputation on that basis.

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Issues: Whether sketch pen and drawing inks were classifiable under sub-heading 3215.10 as writing inks, and whether marker inks and hi-liter inks were classifiable under sub-heading 3215.90 as other inks.

Analysis: The tariff heading covered printing inks, writing or drawing inks and other inks. The head notes under the HSN were treated as relevant for construing the scope of the entry. On that basis, drawing inks were held to fall within the scope of writing inks for sub-heading 3215.10. At the same time, marker inks and hi-liter inks were regarded as specialised inks distinct from ordinary writing inks and therefore falling within the category of other inks under sub-heading 3215.90.

Conclusion: Sketch pen and drawing inks were classified under sub-heading 3215.10, while marker inks and hi-liter inks were classified under sub-heading 3215.90.

Final Conclusion: The classification dispute was resolved by separating ordinary writing and drawing inks from specialised marker and hi-liter inks, and the matter was sent back for recomputation accordingly.

Ratio Decidendi: For tariff classification, the scope of the heading may be ascertained from the statutory heading read with the HSN notes, and inks specifically falling within the wider notion of writing inks are classifiable accordingly, while specialised inks not covered by that scope fall under the residuary entry.

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