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Issues: Whether fusible interlining cloth, being a partially coated cotton fabric not produced by the dot printing process, was classifiable under Tariff Heading 59.03 or under Tariff Heading 52.06.
Analysis: The dispute turned on the interaction between Chapter Note 2(a) and Chapter Note 2(c) of Chapter 59. A coating visible to the naked eye did not, by itself, take the fabric out of the relevant chapter note where the fabric was only partially or discretely coated. However, Chapter Note 2(c) specifically covered only partially or discretely coated textile fabrics where the coating was by the dot printing process. Since the finding was that the fabric in question was not dot printed, the condition for classification under Heading 59.03 was not satisfied.
Conclusion: The fabric was not classifiable under Tariff Heading 59.03 and the classification adopted by the assessee under Tariff Heading 52.06 was sustained.
Ratio Decidendi: A partially or discretely coated textile fabric falls under Tariff Heading 59.03 only when the coating is by the dot printing process; mere visibility of the coating is insufficient.