Specific tariff classification for quicklime prevailed, placing imported goods under the express heading and negating differential duty, interest and penalty.

Tariff classification of imported quicklime is presented on the basis that specific coverage under CTH 2522 1000 prevails over classification under CTH 2825 9090. The text states that Heading 2522 expressly covers quicklime, slaked lime and hydraulic lime, whereas Heading 2825 applies to inorganic bases and chemically defined compounds only where the mineral product has been converted into a separate chemical product. It also notes that the goods were not mixtures requiring application of the general interpretative rules for competing headings. On that basis, the contrary classification was rejected and the related differential duty, interest and penalty were stated not to survive.

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Issues: Whether imported quick lime was classifiable under CTH 2522 1000 or under CTH 2825 9090, and whether the demand of differential duty, interest and penalty could be sustained.

Analysis: The disputed goods were found to be quicklime, a product specifically covered by Heading 2522, which expressly provides for quicklime, slaked lime and hydraulic lime. Heading 2825 was held to cover inorganic bases and other chemically defined compounds, and calcium oxide and hydroxide could fall there only when the mineral product has been converted into a separate chemical product. The goods in the present case were not mixtures requiring resort to the general interpretative rules for competing headings. The prior decisions on the same commodity were also relied upon, including the view that quick lime remains classifiable under Heading 2522.

Conclusion: The goods were held classifiable under CTH 2522 1000 and not under CTH 2825 9090; the impugned classification, duty demand, interest and penalty did not survive.

Final Conclusion: The appeal succeeded and the assessee obtained relief on classification, with the contrary demand set aside.

Ratio Decidendi: Where a tariff heading specifically covers quicklime, the commodity must be classified under that specific heading and not under a more general residual heading meant for chemically defined inorganic bases or other compounds.

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