Tariff classification of corrugated sheets as paperboard goods meant no surviving duty demand under the exemption framework.

Corrugated paper and paperboard cleared as sheets without corrugated boxes were treated as classifiable under Tariff Item 48081000. The tariff entry for heading 4819 covers cartons, boxes and cases of corrugated paper or paperboard, and goods falling within heading 481910 are linked to Notification No. 04/2006-CE. Even if the goods were viewed as not fitting 48191010, they could only move to the residual description under 48191090; however, the same duty rate applied under 48081000 and under 48191010 read with the exemption for the relevant period. On that basis, no duty demand could survive and the Revenue's challenge failed.

---

---

Issues: Whether corrugated sheets or plates cleared without corrugated boxes were classifiable under Tariff Item 48191090 and, if so, whether they were outside the scope of Notification No. 04/2006-CE; alternatively, whether the goods were correctly classifiable under Tariff Item 48081000.

Analysis: The entry for Tariff Item 4819 covers cartons, boxes and cases of corrugated paper or paperboard, and the exemption entry under Notification No. 04/2006-CE applies to goods falling under heading 481910. On the tariff description, even if the goods are not treated as boxes under 48191010, they would still fall within the residual description under 48191090. In any event, corrugated paper and paperboard cleared as sheets without boxes are appropriately classifiable under Tariff Item 48081000. The duty rate under 48081000 and under 48191010 read with the exemption notification is the same for the relevant period, so no duty demand could survive.

Conclusion: The goods were rightly treated as classifiable under Tariff Item 48081000, the demand was not sustainable, and the Revenue's challenge failed.

---