Tyre exemption classification depends on full technical specifications, not rim size alone, when determining saloon-car eligibility.

Tyre classification for exemption purposes must turn on the full technical profile of the product, not rim size alone. In deciding whether tyres of specification 6.70-15 qualified as tyres for saloon cars under Notification No. 41/89-C.E., the tribunal looked to all relevant characteristics, including ply rating and other technical specifications that distinguish saloon-car tyres from tyres for light commercial or other vehicles. Technical material from the assessee, supported by affidavits, was accepted, while the department produced no rebuttal evidence. On that basis, the exclusion for motor vehicles other than saloon cars was not established, and the exemption claim was sustained.

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Issues: Whether tyres of specification 6.70-15 were entitled to exemption under Notification No. 41/89-C.E. dated 1-3-1989 as tyres for saloon cars, or were excluded as tyres for motor vehicles other than saloon cars.

Analysis: The relevant distinction was not to be drawn from rim size alone. The correct classification depended on all technical parameters, including ply rating and other specifications, which differentiate tyres for saloon cars from tyres for light commercial or other motor vehicles. The respondents produced technical material from the I.T.T.A.C. Data Manual and supporting affidavits, while the department produced no material to rebut that evidence. On that basis, the department's assertion that the tyres fell within the exclusionary entry remained unsubstantiated.

Conclusion: The tyres were treated as falling within the exemption claimed by the respondents, and the department's appeal failed.

Final Conclusion: The exemption claim was sustained on the evidence of technical specifications, and the departmental challenge was rejected.

Ratio Decidendi: Where tariff or exemption classification turns on product use, all relevant technical characteristics must be considered, and an unsubstantiated departmental assertion cannot displace technical evidence produced by the assessee.

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