Tariff classification of metal goods turns on physical characteristics and Chapter 72 description, not the assessee's product label.

Classification under Chapter 72 depended on the product's physical characteristics and the tariff description, not the assessee's nomenclature. On examination, the goods were found to have a rectangular cross-section, uneven thickness, and a width of less than 600 mm; technical opinion also supported treatment as iron strip. Applying Chapter Note 1(k), the product answered the description of flat-rolled products in coils or straight lengths and therefore fell under Heading 7211.59 rather than Heading 7214.90. The departmental classification was sustained.

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Issues: Whether the manufactured goods were classifiable as other bars and rods under Heading 7214.90 of the Central Excise Tariff Act, 1985 or as flat-rolled products of width less than 600 mm under Heading 7211.59.

Analysis: The classification dispute turned on the nature of the product on physical examination and the tariff description in Chapter 72. The product was examined by the department in the presence of the appellant and was found to have a rectangular cross-section with uneven thickness and width of less than 600 mm. The technical opinion relied upon by the department also supported the view that the dimensions fell within the range of iron strip. Chapter Note 1(k) to Chapter 72 was considered, under which flat-rolled products are rolled products of solid rectangular cross-section in the form of coils or straight lengths satisfying the prescribed dimensional criteria. On the evidence, the product answered the description of flat-rolled products rather than other bars and rods.

Conclusion: The goods were correctly classified under Heading 7211.59 and not under Heading 7214.90.

Final Conclusion: The assessee's classification claim failed, and the departmental classification was sustained.

Ratio Decidendi: Where the product's physical characteristics and technical opinion establish that it answers the tariff description of flat-rolled products, classification must follow that description notwithstanding the assessee's contrary nomenclature.

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