Tariff classification turns on actual nature and use of goods, not invoice description, for interleaved carbon paper.

For tariff classification, the actual nature and use of goods prevails over the description used in invoices. Interleave carbon paper supplied as computer stationery in sets and as interleaved carbon sets did not fit Heading 48.20 in substance, so the mere bill description could not justify that classification. On the facts noted, the goods were held not classifiable under Heading 48.20 of the Central Excise Tariff Act, 1985, and the classification upheld by the Commissioner (Appeals) was sustained.

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Issues: Whether interleave carbon paper used as computer stationery in sets was classifiable under Heading 48.20 or Heading 48.16 of the Central Excise Tariff Act, 1985.

Analysis: The Revenue did not dispute that the goods were used as computer stationery in sets and as interleaved carbon sets. On that factual basis, the description used in the bills could not by itself justify classification under Heading 48.20 when the goods did not answer that heading in substance.

Conclusion: The goods were not classifiable under Heading 48.20 of the Central Excise Tariff Act, 1985, and the Commissioner (Appeals) was in upholding the assessee's classification.

Ratio Decidendi: For tariff classification, the actual nature and use of the goods prevails over mere description in invoices when the substantive characteristics do not fit the revenue's proposed heading.

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