Customs classification of drop forgings: HSN notes and Rule 2(a) supported Chapter 82, not Chapter 72.

Drop forgings intended for machining into hand tools were treated as classifiable under Chapter 82, not Chapter 72, for central excise purposes. The classification was tested against the HSN Explanatory Notes, which excluded drop forgings from Chapter 72, and Rule 2(a) of the Interpretative Rules was applied to support Chapter 82 coverage. The factual findings below were not displaced by any contrary material, and the cited authorities were held not to govern the goods in question. The claim for Chapter 72 classification therefore failed, and the goods were held classifiable under Chapter 82 against the assessee.

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Issues: Whether drop forgings were classifiable under Chapter 72 or under Chapter 82 for central excise purposes.

Analysis: The product was described as drop forgings meant for machining into hand tools. The classification was tested against the HSN Explanatory Notes, which excluded drop forgings from Chapter 72. Applying Rule 2(a) of the Interpretative Rules, the appellate authority had held that such goods fell under Chapter 82. No material was produced to dislodge the factual findings recorded below, and the cited case law did not cover the present goods.

Conclusion: The claim for classification under Chapter 72 failed and the goods were held classifiable under Chapter 82, against the assessee.

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