Tariff classification cannot change merely because a notification mentions Chapters 84 and 85 without examining the goods' true nature.

Goods classified as iron and steel castings could not be reclassified to Chapters 84 or 85 merely because Notification No. 223/88 referred to those tariff headings. The classification change required a merits-based finding that the goods had ceased to answer the earlier description and had in substance become machinery parts. In the absence of such a finding, reliance on the notification alone was insufficient. The reclassification was therefore unsustainable, and the earlier treatment of the goods was restored.

---

---

Issues: Whether the goods manufactured by the appellant could be reclassified from iron and steel castings to Chapter 84 or Chapter 85 merely because Notification No. 223/88 dated 23-06-1988 referred to those tariff headings.

Analysis: The classification adopted earlier treated the products as iron and steel castings. The reclassification was made only by relying on the notification without a merits-based examination of whether the goods had ceased to answer the earlier description. In the absence of a finding that the nature of the goods justified a shift to machinery parts under Chapters 84 or 85, the change in classification could not be sustained.

Conclusion: The reclassification was unsustainable and the appeal was allowed.

Final Conclusion: The impugned classification order was set aside and the earlier treatment of the goods was restored.

---