Classification of unmachined steel castings turned on their stage of processing and retained character as castings.

Goods supplied as unmachined steel castings, later subjected to machining, grooving and coupling by the buyer, remained classifiable as castings because they had not acquired the essential character of rolls. The material showed that the articles were only at the stage of castings undergoing proof machining, and the Department did not rebut the buyer's letter relied on by the assessee. On that basis, the classification adopted was Heading 73.25 rather than Heading 84.55 under the Central Excise Tariff Act, 1985.

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Issues: Whether the goods manufactured by the assessee were classifiable under Heading 73.25 or under Heading 84.55 of the Central Excise Tariff Act, 1985.

Analysis: The dispute turned on whether the goods had advanced beyond the stage of castings and acquired the specific character of rolls. The evidence relied upon by the assessee, including the customer's letter, showed that the goods were supplied as unmachined steel castings and were subjected to further machining, grooving and coupling by the buyer. The Department did not rebut this material. In these circumstances, the goods were only at the stage of castings undergoing proof machining and had not acquired the essential character of rolls. The principle applied was that castings remain classifiable as castings until they emerge from the mould and reach the stage of proof machining.

Conclusion: The goods were classifiable under Heading 73.25 and not under Heading 84.55, and the appeal succeeded on merits.

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