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Issues: Whether the product manufactured by the respondents was classifiable under Heading 4901.10 as claimed by the Revenue or under Heading 4901.90 as approved by the Commissioner (Appeals).
Analysis: The classification dispute turned on whether the goods had the essential characteristics of transfers capable of being transferred to a permanent surface. The Commissioner (Appeals), after referring to the HSN Explanatory Notes and verification, found that the product consisted of laminated printed sheets and was not practically transferable as a transfer. That finding was not rebutted by the Revenue.
Conclusion: The impugned classification under Heading 4901.90 was upheld and the Revenue's appeal was rejected.
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