Classification of offset litho paper plates turns on essential character, with printing plates prevailing over coated paper heading.

Imported offset litho paper plates were treated as master printing plates for offset printing, because their essential character and commercial identity were that of printing plates even though they were paper-based. Heading 84.34 was applied as the more specific tariff entry for printing plates, while Heading 48.01/21 for coated paper was regarded as the more general description. Explanatory notes relied on by the Revenue were considered persuasive only and could not override the tariff wording where the goods answered the description of printing plates. The classification under Heading 84.34 was therefore preferred over the coated paper heading.

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Issues: Whether the imported offset litho paper plates were classifiable under Heading No. 84.34 of the First Schedule to the Customs Tariff Act, 1975 as printing plates, or under Heading No. 48.01/21 as coated paper.

Analysis: The goods were master printing plates made of coated paper and were used directly for offset printing. Their essential character was that of printing plates, and the fact that they were paper-based did not change that identity. The competing heading for paper was more general, whereas Heading No. 84.34 specifically covered printing plates. The explanatory notes relied on by the Revenue were persuasive only and could not displace the tariff entry where the goods answered the description of printing plates. The commercial and popular understanding of the goods also supported classification as printing plates rather than as ordinary coated paper.

Conclusion: The goods were correctly classifiable under Heading No. 84.34 and not under Heading No. 48.01/21, and the classification adopted by the lower authorities was set aside in favour of the appellants.

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