Newsprint classification depends on the prescribed ISO fibre test; BIS-based laboratory reports were unreliable for reclassification.

Imported paper in reels remained classifiable as newsprint under Heading 4801.00 because the fibre composition requirement had to be tested in the manner prescribed by the HSN Explanatory Notes, namely ISO 9184/1-3. Laboratory reports based on BIS standards were unreliable for reclassification when the analyst confirmed that the prescribed ISO method was not followed, and cross-examination showed that different methods could yield different results. The supplier's certificate also supported the declared composition. On that basis, the contrary departmental reports could not be safely relied upon, and reclassification was not justified.

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Issues: Whether the imported paper in reels was classifiable as newsprint under Heading 4801.00, and whether the laboratory test reports could be relied upon when fibre composition testing was not done in accordance with the ISO standard prescribed in the HSN Explanatory Notes.

Analysis: Newsprint under Chapter 48 requires, inter alia, that not less than 65% by weight of the total fibre content consist of wood fibres obtained by a mechanical or chemi-mechanical process. The HSN Explanatory Notes specifically indicate that fibre composition should be determined by ISO 9184/1-3 to ensure uniformity and to avoid discrepancies caused by differing methods. The samples in the present case were tested by adopting BIS standards, not ISO 9184/1-3, and the cross-examination of the analyst confirmed that the prescribed ISO method was not followed. Since different testing standards can produce different results, the reports from the departmental laboratories could not safely be accepted for reclassification. The supplier's certificate also supported the declared composition.

Conclusion: The imported goods were correctly classifiable as newsprint under Heading 4801.00, and the contrary test reports were not reliable for reclassification.

Final Conclusion: The demand based on reclassification could not be sustained, and the assessee was entitled to the relief arising from acceptance of the declared classification.

Ratio Decidendi: Where the HSN Explanatory Notes prescribe a specific ISO method for determining fibre composition, laboratory reports based on a different method cannot be relied upon to deny newsprint classification.

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