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Issues: Whether goods described as "Architectural Decorative Designer Wall Panel Articles of Stainless Steel of different shapes, sizes and finishes with or without drilled holes in corners" are classifiable under Customs Tariff Heading 7308 90 90 or 7326 90 60 as contended by the applicant, or under another heading of the Customs Tariff Act, 1975.
Analysis: The Authority examined the product description, manufacturing process, dimensions (thickness range 0.4 mm to 3 mm), surface treatments (polishing, embossing, etching, PVD coating, PVC lamination etc.), and applicable statutory and explanatory provisions including Chapter 72 notes and HSN Explanatory Notes. The Authority applied the General Rules for the Interpretation of the Import Tariff, observing that the finishing operations enhance appearance or properties but do not alter the fundamental identity of the goods. Chapter 72 Note 1(k) and the Explanatory Notes treat perforated, polished or coated flat-rolled products as remaining flat-rolled products provided they do not assume the character of articles of other headings. The Authority found that the panels retain the essential character of flat-rolled stainless-steel products and are not structural components (beams, columns, frames) falling under Heading 7308, nor are they residuary "other articles" under Heading 7326 where a more specific heading (7219) applies. Rule 1 and Rule 6 of the GIR were applied to determine the appropriate heading at the sub-heading level.
Conclusion: The goods are classifiable under Customs Tariff Heading 7219 90 90 as "Other flat-rolled products of stainless steel" and not under Headings 7308 90 90 or 7326 90 60.