Tariff classification of patta/patti as pieces, not strips, upheld under Heading 7208.00

Patta/patti were treated as pieces roughly shaped by rolling or forging, not as strips, because the goods were consistently understood by that name and prior rulings had excluded them from the meaning of strips for the relevant tariff period. In the absence of a tariff definition of strip, the Tribunal followed earlier precedent and classified the goods under Heading 7208.00 rather than sub-headings 7211.31 or 7211.39. The Revenue's challenge failed, and the classification under Heading 7208.00 was upheld.

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Issues: Whether patta/patti were correctly classifiable under sub-heading 7208.00 of the Central Excise Tariff and not under sub-headings 7211.31 and 7211.39 as strips.

Analysis: The Tribunal noted that the goods were consistently known as patta/patti and that earlier decisions had already held such goods to be outside the scope of strips for tariff classification. It relied on its prior rulings that, in the absence of a definition of strip for the relevant period and in view of the accepted classification approach, patta/patti were to be treated as pieces roughly shaped by rolling or forging rather than as strips. The earlier view was also supported by precedent holding that the same goods fell under Heading 7208.00 and not under Heading 7211.00.

Conclusion: Patta/patti were held to be classifiable under sub-heading 7208.00 and not under sub-headings 7211.31 and 7211.39. The Revenue's appeals failed.

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