Tariff classification of book binding cloth upheld under Heading 59.01 based on the goods' description and use.

Book binding cloth used for book binding and coated with amylaceous substances was held to fall under Tariff Heading 59.01 rather than Tariff Heading 52.06. Classification turned on whether the goods answered the description of the relevant tariff heading, and the fact that similar goods of another assessee were classified differently in another Commissionerate was treated as irrelevant. The stated position was that the goods squarely met the description of Heading 59.01, so the lower authority's classification was upheld.

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Issues: Whether the book binding cloth was correctly classified under Tariff Heading 59.01 or was classifiable under Tariff Heading 52.06.

Analysis: The goods were admittedly used for book binding and were coated with amylaceous substances. For classification, the controlling test is whether the goods answer the description of the tariff heading under which they are assessed. The fact that similar goods of another assessee were classified differently in another Commissionerate was held to be irrelevant. Since the goods squarely fell within the description of Tariff Heading 59.01, the lower authority's classification was upheld.

Conclusion: The goods were classifiable under Tariff Heading 59.01 and not under Tariff Heading 52.06.

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