Improved wood classification turns on barrel-making processes, and CKD oak casks remained dutiable under the tariff.

Oak wood casks imported in CKD form were treated as "improved wood" because the barrel-making processes applied to them-steaming, bending, firing, trussing, toasting and crozing-amounted to physical treatment under the tariff explanation. The Tribunal noted that the goods were fully manufactured barrels dismantled into parts, and that such treatment gave the wood the characteristics required by Item 16B of the Central Excise Tariff. As a result, countervailing duty was properly levied and exemption under Notification No. 48/79-Cus. was not available.

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Issues: Whether oak wood casks imported in CKD condition were liable to countervailing duty as "improved wood" under Item 16B of the Central Excise Tariff, and whether exemption under Notification No. 48/79-Cus. dated 1-3-1979 was available.

Analysis: The relevant tariff explanation treated "improved wood" as wood subjected to chemical or physical treatment and thereby acquiring greater density, hardness, mechanical strength, or resistance. On the evidence placed before it, the imported oak wood casks, though brought in CKD form, had undergone manufacturing processes such as steaming, bending, firing, trussing, toasting, and crozing, which involved physical treatment. The Tribunal also noted that the goods were fully manufactured barrels dismantled into parts, and that such processes satisfied the tariff test of physical treatment.

Conclusion: The imported goods were correctly classified under Item 16B as improved wood, countervailing duty was properly levied, and the assessee was not entitled to relief.

Final Conclusion: The order of the lower authority was upheld and the appeal failed.

Ratio Decidendi: Wood subjected to recognised barrel-making processes involving physical treatment, even when imported in CKD form, falls within a tariff definition of improved wood.

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