Tariff classification of inks depends on HSN notes, with writing inks separated from specialised marker and lettering inks.

Tariff classification of inks under Heading 3215.10 turned on the scope of "writing ink" as read with the HSN notes. Inks used in sketch pens and drawing pens were treated as writing inks and classified under Heading 3215.10. Specialised inks such as marker inks, rapidograph inks, highlighting inks and croquill lettering pen inks were treated as other inks and classified under Heading 3215.90. The governing principle is that classification must follow the statutory entry and HSN notes, and inks not ordinarily answering the description of writing ink fall under the residuary ink entry.

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Issues: Whether inks manufactured for use in different writing instruments were classifiable as writing ink under Heading 3215.10 or as other inks under Heading 3215.90.

Analysis: The classification turned on the scope of writing ink under the tariff entry and the corresponding HSN notes. On that basis, inks used in sketch pens and drawing pens were treated as writing inks, while specialised inks such as marker inks, rapidograph inks, highlighting inks and croquill lettering pen inks were treated as other inks.

Conclusion: The classification was held to be under Heading 3215.10 for ordinary writing-related inks, and under Heading 3215.90 for marker, rapidograph, highlighting and croquill lettering pen inks.

Final Conclusion: The appeal was disposed of by applying a split classification between writing ink and other inks depending on the nature and use of the ink.

Ratio Decidendi: For tariff classification, the scope of the relevant heading must be determined with reference to the statutory entry and HSN notes, and specialised inks not ordinarily answering the description of writing ink are classifiable under the residuary ink entry.

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