Classification of shaped steel templates as manufactured goods sustained over ordinary corrugated sheet treatment.

Hot rolled steel sheets cut and shaped into templates or moulds with definite contours, size and specific utility were treated as manufactured goods with a distinct commercial identity, not as ordinary corrugated steel sheets. Explanation XVIII to Tariff Item 25 was held inapplicable because the goods were not mere corrugated sheets in common parlance. The process of cutting, trimming and shaping amounted to manufacture, so classification followed the product's actual identity. The goods were therefore classifiable under Tariff Item 68 of the erstwhile Central Excise Tariff up to 28-2-1986 and under sub-heading 8474.00 from 1-3-1986, and the refund claims failed.

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Issues: (i) Whether hot rolled steel sheets converted into templates/corrugated sheets retained classification under Tariff Item 25 or were classifiable as manufactured goods under Tariff Item 68 of the erstwhile Central Excise Tariff and, after 1-3-1986, under sub-heading 8474.00 of the Central Excise Tariff Act, 1985.

Analysis: The product was found to be in the form of templates or moulds with definite shapes, contours and specific utility, and not plain or corrugated steel sheets in the ordinary sense. The process of cutting, trimming and giving the sheets a definite shape and size resulted in a product having a distinct identity and use. Explanation XVIII to Tariff Item 25 was held inapplicable because the goods were not mere corrugated sheets. In the absence of evidence that the goods were known in common parlance as corrugated steel sheets, the classification was determined on the basis of the product's actual commercial identity and the process was treated as manufacture.

Conclusion: The goods were not classifiable under Tariff Item 25. They were correctly classifiable under Tariff Item 68 of the erstwhile Central Excise Tariff upto 28-2-1986 and under sub-heading 8474.00 from 1-3-1986.

Final Conclusion: The refund claims failed and the classification adopted by the department was sustained, with both appeals dismissed.

Ratio Decidendi: When steel sheets are processed into templates having a distinct shape, contour and commercial identity, the product acquires a new character and is classifiable according to its specific manufactured identity rather than as ordinary corrugated sheets under a more general tariff entry.

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