Customs classification must rest on complete evidence and tariff standards, not partial lab reports or uncertain expert opinion.

Imported goods could not be classified as High Speed Diesel merely on the basis of incomplete laboratory reports and unclear expert evidence. The classification turned on the Customs Tariff Act, 1975, the chapter note defining High Speed Diesel by reference to IS 1460:2005, and General Rules for Interpretation Rules 1 and 4. The reports did not establish conformity with all prescribed parameters, and the evidence did not clarify the significance of untested parameters or flash point. The proper test was whether the goods were most akin to the specified product, and the record did not justify treating them as High Speed Diesel; the customs classification was therefore unsustainable.

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Issues: Whether the imported goods were classifiable as High Speed Diesel or Base Oil, and whether the customs authorities had proved the alleged classification on the basis of the laboratory reports and expert evidence.

Analysis: The classification dispute turned on the statutory scheme under the Customs Tariff Act, 1975, particularly the chapter note defining High Speed Diesel by reference to Indian Standard IS 1460:2005 and the General Rules for Interpretation, especially Rule 1 and Rule 4. The laboratory reports relied upon by the Department were found to be inconclusive because none of them established conformity with all the prescribed parameters, and even the report from the Indian Oil Corporation Limited only noted conformity with the parameters tested at that laboratory. The expert evidence was also found to be unclear on the significance of the untested parameters and the flash point, which cast doubt on the conclusion that the goods were High Speed Diesel. The standard for classification was held to be whether the goods were most akin to the specified product, not merely whether a degree of probability supported the Department's view. On the record, the evidence did not justify treating the goods as High Speed Diesel.

Conclusion: The goods were not proved to be High Speed Diesel and the classification adopted by the customs authorities could not be sustained; the appellants succeeded.

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