Quicklime classification under customs tariff turned on purity, with low-calcium-oxide material falling under the specific quicklime heading.

Quicklime imported for use in manufacturing was held classifiable under Customs Tariff Item 2522 1000 because the chemical analysis showed calcium oxide content below 98%, and the tariff scheme and HSN notes treat heading 2522 as the specific entry for quicklime. Heading 2825 9090 applies to purified calcium oxide or calcium hydroxide in the pure state, ordinarily of high purity, so it could not be preferred on the facts. The goods were therefore correctly classified under the specific quicklime heading, not the alternative heading for purified inorganic compounds.

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Issues: Whether the imported quicklime was classifiable under Customs Tariff Item No. 2522 1000 as claimed by the assessee, or under Customs Tariff Item No. 2825 9090 as assessed by the Revenue.

Analysis: The imported goods were quicklime used in the assessee's manufacturing process. The chemical analysis certificates showed calcium oxide content below 98%. The classification dispute turned on the tariff scheme and the HSN notes, under which quicklime is covered by heading 2522, while heading 2825 applies to purified calcium oxide or calcium hydroxide in the pure state, ordinarily of high purity. Since the goods were not shown to have the requisite purity of 98% or more, and the specific heading for quicklime was available, the residuary or alternative heading under 2825 could not be preferred.

Conclusion: The goods were rightly classifiable under Customs Tariff Item No. 2522 1000 and not under Customs Tariff Item No. 2825 9090.

Ratio Decidendi: Quicklime with calcium oxide content below 98% remains classifiable under the specific tariff heading for quicklime, and not under the heading for purified calcium oxide or other residuary inorganic compounds.

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