Strict tariff classification favours pieces roughly shaped by rolling or forging where pattas/pattis do not meet the strips or hoops description.

Stainless steel pattas/pattis were classified by strict reference to the tariff description applicable during the relevant period. Because the goods were irregular in shape and size and were not shown to satisfy the essential description of strips or hoops, the competing strips/hoops entry was rejected. Earlier Tribunal decisions on the same tariff period supported classification under pieces roughly shaped by rolling or forging of iron or steel, not elsewhere specified, and that description was applied here. The result was in favour of the assessee, with the relevant tariff item governing the goods.

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Issues: Whether the stainless steel products known as pattas/pattis were classifiable as pieces roughly shaped by rolling or forging of iron or steel, or as hoops/strips under the relevant tariff items.

Analysis: The classification had to be determined with reference to the tariff structure as it stood during the relevant period. The goods were described in trade as pattas/pattis, were irregular in shape and size, and were not shown to answer the description of strips or hoops. The earlier Tribunal decisions relied on had already held that such goods, for the material period, fell under the entry for pieces roughly shaped by rolling or forging, not elsewhere specified, rather than the entry for hoops/strips. Applying the same reasoning, the relevant tariff description was held to govern the goods and the revenue's classification under the strips/hoops entry was rejected.

Conclusion: The goods were correctly classifiable as pieces roughly shaped by rolling or forging of iron or steel under the relevant tariff item, and not as hoops/strips; the view was in favour of the assessee.

Ratio Decidendi: For tariff classification, the specific description in the tariff entry must be applied strictly to the goods as they are, and where the goods do not satisfy the essential description of a competing entry, they cannot be classified under that competing entry merely because of a broad commercial resemblance.

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