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Issues: Classification of filing cabinets and plan filing cabinets under the Central Excise Tariff.
Analysis: The filing cabinets were treated as office furniture designed to be placed on the ground and not as desk or office equipment. Applying Chapter Note 2 of Chapter 94, the items were held to fall under Heading 94.03. The plan filing cabinets were found to be similar to filing cabinets and were given the same classification.
Conclusion: The classification under Heading 94.03 was upheld for filing cabinets and plan filing cabinets, and the Revenue's challenge succeeded on this issue.