The CESTAT allowed the appeal, holding that the PVC Resin SP 660...

The CESTAT allowed the appeal, holding that the PVC Resin SP 660 Suspension Grade must be classified under CTH 3904 2110 as poly(vinyl chloride) resins, rather than under the residual CTH 3904 1090. The Tribunal emphasized the primacy of classifying goods under the most specific tariff heading as per the General Rules for the Interpretation of Import Tariff, specifically Rule 3(a). It was found that the appellant's goods were not mixed with any other substances, corroborated by test reports, and thus constituted prime material. The Commissioner (Appeals) erred by differentiating the appellant's goods from similar goods previously classified and by relying on semantics rather than classification principles. The impugned order was set aside, affirming the specific tariff heading 39042110 and the applicability of the relevant notification benefits.