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Issues: Whether the goods described as forged shapes of non-alloy steel and forged shapes of alloy steel were classifiable under Chapter 72 of the Central Excise Tariff Act, 1985 as claimed by the assessee or under Heading 73.26 as forged articles of iron and steel.
Analysis: The goods were found to have irregular shapes and cross-sections and to be forged products made with dies, ready for machining. They did not satisfy the description of angles, shapes and sections under Chapter 72, which require a uniform solid section along the whole length, nor were they merely pieces roughly shaped in the manner suggested by the assessee. On the basis of their character as forged products not answering the Chapter 72 description, classification under the claimed sub-headings was held to be inappropriate.
Conclusion: The correct classification was under Heading 73.26 as forged articles of iron and steel, against the assessee and in favour of the Revenue.
Ratio Decidendi: Goods having irregular shape and cross-section, and being forged articles requiring machining, are not classifiable as angles, shapes and sections under Chapter 72 but fall under the heading applicable to forged articles of iron and steel.