Common parlance classification controls tariff entry for Pan Chatni; manufacturer's label cannot override the proper heading.

Tariff classification of Pan Chatni turned on its composition, use and common parlance identity, not the label adopted by the manufacturer. Applying noscitur a sociis, the expression "sauces, ketchup and the like" was confined to edible accompaniments used with food generally, and the product used with pan did not fall within that entry. The article was therefore held classifiable as an edible preparation under sub-heading 2107.91, and the claimed chatni exemption could not apply once the goods were outside the relevant tariff entry. The departmental classification was confirmed and the assessee's appeals failed.

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Issues: Whether the product sold as "Pan Chatni" was classifiable as "sauces, ketchup and the like and preparations thereof" under sub-heading 2103.11, or as an edible preparation under sub-heading 2107.91, and whether the claimed exemption for chatni applied.

Analysis: The product was examined in the light of its composition, use, commercial understanding, and the manner in which the tariff expression "and the like" had to be read. Applying the principle of noscitur a sociis, the words associated with sauces and ketchup were confined to goods having the character of edible accompaniments used with food. The product in question was used with pan, not with eatables generally, and its description by the manufacturer as "chatni" did not determine its tariff identity. Classification depended on the nature of the goods and their common parlance understanding, not on the label affixed by the assessee. The exemption notification could not alter the proper classification once the goods were found to fall outside the claimed entry.

Conclusion: The product was not chatni or a like preparation under sub-heading 2103.11. It was correctly classifiable under sub-heading 2107.91, and the exemption claim failed. The conclusion was against the assessee and in favour of Revenue.

Final Conclusion: The appeals failed, and the departmental classification under sub-heading 2107.91 stood confirmed.

Ratio Decidendi: Tariff classification must be determined by the common parlance identity, commercial understanding, and use of the goods, and a manufacturer's label cannot displace the proper entry; an exemption notification cannot change the classification of goods from one tariff item to another.

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