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Issues: Whether the change in tariff description shifting the goods from one tariff entry to another became effective from the date of introduction of the Finance Bill or only from the date of enactment.
Analysis: The dispute concerned the effective date of a tariff restructuring that moved the goods from one sub-heading to another. The Tribunal followed the principle that a proposed shift of goods from one tariff item to another is not covered by the Provisional Collection of Taxes Act, since that Act does not extend to shifting goods to a different entry. On that basis, the change in tariff description could not operate from the date of introduction of the Bill merely because the Bill was placed before Parliament.
Conclusion: The change in tariff description took effect only from the date of enactment, not from the date of introduction of the Finance Bill, and the appeals succeeded.