Plastic cassette housings classified as articles of plastics, with exemption benefit upheld under the applicable notification.

Plastic housings for video cassettes, when supplied without magnetic tape or other recording media, were treated as articles of plastics under Tariff Heading 39.26 rather than as prepared unrecorded media under Tariff Heading 85.23. The Tribunal relied on an earlier Tribunal decision and the supporting Board circular to hold that the classification issue had already been settled in favour of Heading 39.26. On that basis, the goods were held entitled to the benefit of Notification No. 132/86-C.E., the impugned order was set aside, and consequential relief followed.

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Issues: Whether plastic housing for video cassettes, without magnetic tape or media, was classifiable under Tariff Heading 39.26 as articles of plastics and entitled to the benefit of Notification No. 132/86-C.E., rather than under Tariff Heading 85.23 as prepared unrecorded media for sound recording or similar recording of other phenomena.

Analysis: The classification dispute had already been decided in an earlier Tribunal order relied upon before the Tribunal, and the Board's circular also supported classification of such goods as articles of plastics. On that basis, the Tribunal accepted the appellant's classification claim under Heading 39.26 and treated the exemption notification as applicable.

Conclusion: The plastic housing for video cassettes was correctly classifiable under Tariff Heading 39.26 and qualified for the benefit of Notification No. 132/86-C.E., not under Tariff Heading 85.23.

Final Conclusion: The impugned order was set aside and the appeal was allowed with consequential relief.

Ratio Decidendi: Where the classification of a product has already been settled by prior Tribunal authority and supported by the relevant circular, plastic housings for video cassettes are to be treated as articles of plastics and the corresponding exemption benefit follows.

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