Broad interpretation of "sports goods" brings playing cards within exemption and supports refund relief.

Playing cards classifiable under Heading 95.04 as games and sports requisites were treated as falling within the expression "sports goods" in Notification No. 73/86. The tariff wording, read with the Harmonised System of Nomenclature, showed no distinction between games and sports, and the Tribunal declined to confine the notification by trade parlance where the language was clear. An administrative circular supported the broader scope of the expression. On that basis, playing cards were held eligible for nil duty treatment and consequential refund relief.

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Issues: Whether playing cards, classified under Heading 95.04 as games and sports requisites, qualified as "sports goods" for the purpose of Notification No. 73/86 dated 10-2-1986 and were therefore entitled to nil rate of duty and refund of duty paid earlier.

Analysis: The notification used the expression "sports goods", while the tariff heading covered "games and sports requisites" without drawing any distinction between sports and games. The wording of the tariff, supported by the Harmonised System of Nomenclature, showed that playing cards were specifically classifiable under Heading 95.04. The expression "sports goods" was held to be of wide import, and the Tribunal declined to restrict it by trade parlance when the tariff language itself was sufficiently clear. The administrative circular also indicated that the expression had a broad scope.

Conclusion: Playing cards fell within the expression "sports goods" in the notification, and the appellants were entitled to the exemption and consequential refund relief.

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