Classification of proof-machined iron castings upheld under tariff entry for castings, with exemption benefit following accordingly.

Unmachined iron cast articles that had undergone only proof machining and no further working remained classifiable as castings under sub-heading 7325.10. The Tribunal applied its settled view on similar goods and held that the Revenue could not reclassify the articles merely by reference to intended end-use. On that basis, the goods were treated as eligible for the consequential benefit of the exemption notifications claimed.

---

---

Issues: Whether unmachined iron cast articles, which had not been worked upon beyond the stage of proof machining, were classifiable under sub-heading 7325.10 and entitled the assessee to the benefit of the relevant exemption notifications.

Analysis: The Tribunal noted that the same classification dispute had already been considered in earlier decisions relating to the assessee and also in the Tribunal's ruling on unmachined iron castings. The goods in question were only castings subjected to proof machining and had not undergone further working. Applying the settled view on classification of such castings, the Tribunal held that the earlier orders governing the same product and issue were applicable and that the Revenue's classification approach was not sustainable.

Conclusion: The goods were held classifiable under sub-heading 7325.10, and the assessee was held entitled to the consequential benefit of the notifications claimed.

Ratio Decidendi: Unmachined iron castings that have not been worked upon beyond proof machining retain their classification as castings under the relevant tariff entry and cannot be reclassified merely on the basis of intended end-use.

---