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Issues: Whether textile floor coverings having a jute ground fabric with a polypropylene surface were classifiable under Chapter sub-heading 5703.20 or under residuary Chapter sub-heading 5703.90.
Analysis: The applicable classification turned on the Chapter and Section Notes governing textile goods. Chapter 57 Note 1 defines carpets and other textile floor coverings by reference to the exposed textile surface when in use, while Section XI Note 2(A) governs products of Chapters 56 to 63 containing two or more textile materials. The Court followed the earlier decisions which held that, where the product is not a piled or looped surface article, the ground fabric is not decisive and the composite textile product must be classified in accordance with the relevant section and chapter notes. On that basis, the presence of polypropylene on the surface did not displace classification as a jute carpet.
Conclusion: The goods were classifiable under Chapter sub-heading 5703.20 and not under Chapter sub-heading 5703.90.
Final Conclusion: The revenue challenge to the classification failed, and the classification adopted by the appellate authority was maintained.
Ratio Decidendi: For composite textile floor coverings of Chapters 56 to 63, classification must follow Section XI Note 2(A) and the relevant chapter notes, and where the article is not a piled or looped surface product, it may be classified according to the textile material treated as governing under those notes rather than by the mere presence of a different surface material.