Tariff classification of plastic ice boxes follows the HSN guidance and Heading 94.03, not Chapter 39 exemption references.

Plastic ice boxes used as insulated containers for keeping contents cold were held classifiable under Heading 94.03, because tariff classification had to follow the heading text, chapter notes and the HSN, which treated ice boxes and similar insulated containers as furniture. Reference in exemption notifications to ice boxes in Chapter 39 did not govern classification, since such notifications cannot control the proper tariff entry on merits. The Revenue's classification under Heading 94.03 was upheld, and Heading 39.24 was rejected.

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Issues: Whether ice boxes manufactured from plastic material and used for keeping contents cold are classifiable under Heading 94.03 of the Central Excise Tariff Act, 1985 as furniture, or under Heading 39.24 as plastic household articles.

Analysis: The product was a movable insulated container made of plastic and used for storing cold drinks. The tariff classification had to be determined from the heading text and the chapter notes, and in case of doubt the HSN was treated as a safe guide because the Central Excise Tariff was aligned with the HSN scheme. The HSN notes specifically treated ice boxes and similar insulated containers as falling under Heading 94.03. The fact that certain exemption notifications referred to ice boxes in Chapter 39 did not control classification, because exemption notifications cannot determine the tariff entry where the proper heading is otherwise ascertainable on merits.

Conclusion: The ice boxes were classifiable under Heading 94.03 and not under Heading 39.24, and the Revenue's classification was upheld.

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