Exemption for iron castings confirmed where the 1.9% carbon-content condition did not apply to distinct tariff entries.

Notification No. 208/83 was available to malleable iron castings under Tariff Item 25(16)(i), because the 1.9% carbon-content requirement in the tariff explanation applied to pig iron and cast iron under Tariff Item 25(1), not to distinct iron castings. The notification covered iron castings, and the presence of steel scrap as an input in the notification table supported the exemption claim. The lower carbon content found in the samples therefore did not justify denial of the benefit, and the Revenue's attempt to extend the 1.9% condition to iron castings failed.

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Issues: Whether the benefit of Notification No. 208/83 was available to malleable iron castings falling under Tariff Item 25(16)(i), and whether the requirement of carbon content of 1.9% or more applied to such castings for claiming the exemption.

Analysis: The relevant tariff explanation made the 1.9% carbon-content criterion applicable to pig iron and cast iron falling under Tariff Item 25(1). That criterion was not shown to govern iron castings falling under Tariff Item 25(16)(i), which are distinct products. Since the notification covered iron castings and steel scrap appeared as an input in the notification table, the lower carbon content found in the samples did not justify denial of the exemption to the assessee.

Conclusion: The notification benefit was rightly extended to the assessee, and the Revenue's attempt to apply the 1.9% carbon-content requirement to iron castings failed.

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