TaxTMI 
TaxTMI 
2021 (10) TMI 149
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....oap, hydrogen peroxide) with acetic acid with the help of Jigger Machine. Thereafter it is subjected to drying range machine for drying. Subsequent to this dried fabric is by adding starch PVA and binder by padding process on Stenter Machine. After completion of this process this fabric is passed through calendar and zero machine. Thereafter this fabric is partially coated by Polyethylene powder having 25 to 45 grams per sq.meters with the help of engraved dotted cylinder. Thus Final Fabrics produced is having partial and porous coating with Polyethylene powder. The fabric so emerged is known as Fusible Interlining fabrics of cotton. Thus from the manufacturing process it is revealed that coating is not carried out with Films.' 3. The appellant has submitted that air and water can easily pass through this fabric and this fabric is easily tearable and washable by hand; that in common parlance the fabric so manufactured is known as Fusible Cotton interlining fabrics and it is supplied to wholesaler, wholesaler to retailer and retailer to tailor for it is used in the collars and cuff of shirt for garments and it's price is below Rs. 100 per sq.metre; that prior to roll out of Goods a....
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....l Excise Tariff Act, 1985. Chapter Note for Heading 5903 of the First Schedule to the Customs Tariff Act, 1975 Heading 5903 applies to: (a) textile fabrics, impregnated, coated, covered or laminated with plastics, whatever the weight per square metre and whatever the nature of the plastic material (compact or cellular), other than: (1) fabrics in which the impregnation, coating or covering cannot be seen with the naked eye (usually Chapters 50 to 55, 58 or 60); for the purpose of this provision, no account should be taken of any resulting change of colour; (2) products which cannot, without fracturing, be bent manually around a cylinder of a diameter of 7 mm, at a temperature between 15oC and 30oC (usually Chapter 39); (3) products in which the textile fabric is either completely embedded in plastics or entirely coated or covered on both sides with such material, provided that such coating or covering can be seen with the naked eye with no account being taken of any resulting change of colour (Chapter 39); (4) fabrics partially coated or partially covered with plastics and bearing designs resulting from these treatments (usually Chapters 50 to 55, 58 or 60); (5) plates....
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....ame: 'Whether the product Fusible Interlining Fabrics of Cotton is correctly classifiable under Chapter 52 or 59?' 7. The appellant has stated that the had approached the Gujarat Authority for Advance Ruling along with the test results of their products which they had obtained from ATIRA, recognized by the Government of India. The Gujarat Authority for Advance Ruling ruled that their product 'Fusible Interlining Fabrics of Cotton' was classifiable under Heading 5903 of the First Schedule to the Customs Tariff Act, 1975(51 of 1975) on the following grounds: (i) On comparing the test results of the sample product/fabric 'fusible interlining fabric of cotton' of the applicant obtained from ATIRA, with the 3 conditions of the explanatory notes to HSN in respect of Heading 5903, all the 3 conditions for classification under Heading 5903 were found to have been fulfilled. (ii) The fabric fusible interlining fabric of cotton' of the applicant was found to be not classifiable under Heading 5208 to 5212 of Chapter 52 of the Customs Tariff Act, 1975 as none of these headings covered laminated fabrics or fabrics coated with plastics. (iii) Reliance was placed on (a)Order No. 33/WBAAR....
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....e naked eye with no account being taken of any resulting change of colour (Chapter 39); (4) fabrics partially coated or partially covered with plastics and bearing designs resulting from these treatments (usually Chapters 50 to 55, 58 or 60); (5) plates, sheets or strip of cellular plastics, combined with textile fabric, where the textile fabric is present merely for reinforcing purposes (Chapter 39); or (6) textile products of heading 5811; (iii) As per the above chapter note, it excludes fabrics having characteristics from Sr.No.1 to 5 above; that it is mentioned the said chapter note as to where the fabrics having characteristics of (1) to (5) will be classified, if not classified under Heading 5903 and that by referring to Explanatory notes to HSN, the GAAR has negated the content of Chapter note 2(a) which is not correct and legal. (iv) The test result obtained by appellant from ATIRA is admitted by GAAR in para 22 of the impugned order and according to the test report dated 02.08.2018, characteristics of the products of the appellant are as under: (1) The product contains 85% and more cotton. (2) The product is polymer coated on one side. Coating cannot be seen ....
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....emperature between 15oC and 30oC (usually Chapter 39); (3) products in which the textile fabric is either completely embedded in plastics or entirely coated or covered on both sides with such material, provided that such coating or covering can be seen with the naked eye with no account being taken of any resulting change of colour (Chapter 39); (4) fabrics partially coated or partially covered with plastics and bearing designs resulting from these treatments (usually Chapters 50 to 55, 58 or 60); (5) plates, sheets or strip of cellular plastics, combined with textile fabric, where the textile fabric is present merely for reinforcing purposes (Chapter 39); or (6) textile products of heading 5811; This heading covers textile fabrics which have been impregnated, coated, covered or laminated with plastics (e.g., poly(vinyl chloride)). Such products are classified here whatever their weight per m2 and whatever the nature of the plastic component (compact or cellular), provided: (1) That, in the case of impregnated, coated or covered fabrics, the impregnation, coating or covering can be seen with the naked eye otherwise than by a resulting change in colour. Textile fabrics in wh....
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....onditions analyzed by GAAR and contention of the appellant are as under: Sr.No. Conditions to be fulfilled as per explanatory notes to HSN Corresponding test results as per ATIRA's test report 01. In the case of impregnated, coated or covered fabrics, the impregnation, coating or covering can be seen with the naked eye otherwise than by a resulting change in colour. The product is polymer coated on one side. Coating cannot be seen with the naked eye. Coating is non-continuous. This coating is different than film coating. Film coating is visible with naked eye. 02. The products are not rigid, i.e. they can, without fracturing, be bent manually around a cylinder of a diameter of 7 mm, at a temperature between 15 degrees centigrade and 30 degrees centigrade. The product can be bent without fracturing around a cylinder of a diameter 7m or more at temperature between 15C to 30C. 03. The textile fabric is not completely embedded in, nor coated or covered on both sides with, plastics. The fabric is not completely embedded in plastic. It is covered with plastic polymer on one side and bears a design like a dot matrix design resulting from coating process. Condition 1 (Para-23....
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.... stipulates that coating must be visible with the naked eye but does not mention polymer coating or film coating, hence this condition is fulfilled' is totally erroneous and reading of the explanatory note is out of context. Condition 2: It is mentioned here that 'is fulfilled as the product can be bent without fracturing around a cylinder of a diameter 7m or more at temperature between 15 degrees C to 30 degrees C.' The appellant has stated that GAAR have ignored that the product having these characteristics is excluded at Sr.No.2 of Chapter 2(a). Condition 3: It is mentioned here that 'is fulfilled as the fabric is not completely embedded in plastic but is covered with plastic polymer on one side and bears a design like a dot matrix design resulting from coating process.' The appellant has stated that the condition no.3 available in explanatory note is- '(3) That the textile fabric is not completely embedded in, nor coated or covered on both sides with, plastics. Products not meeting the requirements of subparagraph(2) or (3) above usually fall in Chapter 39. However, textile fabric coated or covered on both sides with plastics where the coating or covering cannot be seen w....
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....6) ELT.782(Tribunal). They have reproduced the full text of the Circular referred above as under: Circular No. 254/88/96-CX dated 18/10/96 [From F.No. 59/3/93-CX.1] Government of India Ministry of Finance Department of Revenue, New Delhi Subject: Classification of Tarpaulin/ Processed waterproofing canvas cloth- Clarification regarding. I am directed to draw your attention to Board's Circular No. 6/91 dated 11.4.91 wherein it was clarified that wax coated canvas cloth would merit classification under heading 59.06 of the Central Excise Tariff if there is formation of visible layer on the surface of the fabric and not merely a change of colour or some residue. If, on the other hand, there is no visible layer formation, then the said wax proofed/ tarpaulin cloth would be classifiable in Chapter 52 of the Central Excise Tariff as water proofed cloth, provided that base fabrics are cotton fabrics. It also clarified therein that a 'layer' should be distinguished from mere presence of residues in uneven patches. 2. It has been represented that the criteria of visible layer formation on the fabric has posed problems in deciding the classification of tarpaulin cloth/ wax coated c....
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....of the First Schedule to the Customs Tariff Act, 1975. (x) Based on the explanatory note of HSN for Chapter 52 and ignoring the Chapter Note 2(a) of Chapter 59, the GAAR has drawn conclusion in para 24.3, 24.4 and 24.5 that the subject fabrics is not classifiable under Chapter 52 but under Chapter Heading 5903 which is not correct; that as discussed in above para, the Chapter note prevails over the Explanatory notes to HSN, accordingly, the decision of GAAR is in contradiction to what is clarified in para 5 by CBEC in the above referred Circular No. 254/88/96-CX dated 18.10.1996; that not only is it also against the General Interpretative Rules which state that 'for legal purposes, classification shall be determined according to the terms of the headings and any relative Section or Chapter notes and, provided such headings or notes do not otherwise require, according to the following provisions.' (xi) In the instant case, Chapter Note 2(a) for heading 5903 specifically excludes the fabrics mentioned at Sr.No.1 to 5 of the note where the appellant's fabric falls under Sr.No.2 along with other exclusion clauses; that in exclusion at Sr.No.2, it is specifically mentioned that such....
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....f Central Excise, Tirunelveli reported at 2019 (365) ELT 345 (Tri-Chennai) has held that: Cloth-Fusible interlining cloth, Classification of-Note2(c) in Chapter 59 of Central Excise Tariff itself no longer in existence and requirements laid down in Chapter Note 2(a) to Heading 5903 ibid read with CBE & C Circulars not satisfied-Impugned goods not to be classified under Heading 59.03 ibid-Impugned order cannot sustain and liable to be set aside. Thus the appellant have relied upon the above decision which is clearly distinguishable from the decisions relied by the GAAR; that the GAAR has not commented or given its findings in their Ruling with regard to the case of M/s. Madura Coats pvt.ltd. vs. CBEC, New Delhi for not considering the appellant's claim. (xiv) Another case which is relied upon by the GAAR is the Ruling of Uttarakhand State Authority for Advance Ruling Order No.11/2019-20 dated 12.03.2020 and the perusal of the order of AAR, Uttarakhand reveals that they have not examined the decision of Madura Coats pvt. ltd. vs. CBEC, New Delhi mentioned above; that the ratio of the two decisions relied upon by the GAAR are not applicable to the appellant's case as in both the....
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....natory notes of the First Schedule; that Rule 1 of the General rules for the interpretation for classification of goods in the schedule provides that 'The titles of sections, chapters and sub-chapters are provided for ease of reference only; for legal purposes, classification shall be determined according to the terms of the headings and any relative Section or Chapter notes. (ii) GAAR has classified their product 'Fusible Interlining Fabrics of Cotton' under Chapter heading No.5903 by mis-reading the Chapter Note.No.2(a) of the said heading. (iii) Chapter note 2(a) of Chapter 59 excludes fabrics having characteristics from Sr.No.1 to 5 of the note from heading 5903 and that by referring to Explanatory notes to HSN, the GAAR has negated the content of Chapter note 2(a). (iv) Comparison of Chapter Note 2(a), Sr.No.1 to 5 with the test result of their product (obtained from ATIRA) clearly suggests that the product is excluded from the chapter heading 5903, but GAAR has extrapolated the issue and has referred to the Explanatory notes of HSN for guidance. (v) The appellant has also submitted a comparative chart of the test results, chapter note no.2 of heading 5903 in the Firs....
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....re excluded from Heading 5903 whereas the criteria mentioned in the explanatory notes to the HSN [marked in bold letters in column(2) below] lays down the conditions which helps in classifying the product under Heading 5903. A comparative chart of the same, which is given below, will help clarify the issue: Chapter Note 2(a) for Heading No.5903 in First Schedule of the Customs Tariff Act, 1975 Explanatory note of Heading No.5903 from HSN for guidance. (1) (2) Heading 5903 applies to: (a) textile fabrics, impregnated, coated, covered or laminated with plastics, whatever the weight per square metre and whatever the nature of the plastic material (compact or cellular), other than: (1) fabrics in which the impregnation, coating or covering cannot be seen with the naked eye (usually Chapters 50 to 55, 58 or 60); for the purpose of this provision, no account should be taken of any resulting change of colour; (2) products which cannot, without fracturing, be bent manually around a cylinder of a diameter of 7 mm, at a temperature between 15oC and 30oC (usually Chapter 39); (3) products in which the textile fabric is either completely embedded in plastics or entirely coated or cove....
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....present merely for reinforcing purposes, are also classified in Chapter 39 (see General Explanatory Note to Chapter 39, part entitled "Plastics and textile combinations", penultimate paragraph). The laminated fabrics of this heading should not be confused with fabrics which are simply assembled in layers by means of a plastic adhesive. These fabrics, which have no plastics showing in cross-section, generally fall in Chapter 50 to 55. In many of the textile fabrics classified here, the plastic material, usually coloured, forms a surface layer which may be smooth or be embossed to simulate e.g. the grain of leather ("leather cloth"). This heading also covers dipped fabrics (other than those of heading 59.02), impregnated to improve their adhesion to rubber, and textile fabrics which are spattered by spraying with visible particles of thermoplastic material and are capable of providing a bond to other fabrics or materials on the application of heat and pressure. 11.3 The appellant has also stated that while examining the test results of their sample product (which they have obtained from ATIRA, Ahmedabad), GAAR compared the Explanatory Notes of HSN with samples and not with the chap....
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.... both sides with such material, provided that such coating or covering can be seen with the naked eye with no account being taken of any resulting change of colour (Chapter 39); (4) fabrics partially coated or partially covered with plastics and bearing designs resulting from these treatments (usually Chapters 50 to 55, 58 or 60); (5) plates, sheets or strip of cellular plastics, combined with textile fabric, where the textile fabric is present merely for reinforcing purposes (Chapter 39); or (6) textile products of heading 5811; 11.4 Also, as per data available online, we find that Ahmedabad Textile Industry's Research Association (commonly known as ATIRA) is an autonomous non-profit association for textile research located in Ahmedabad and is the largest association for textile research & allied industries in India which was established on 13 December 1947 and was recognized by the Council of Scientific and Industrial Research under the Ministry of Science and Technology, Government of India. In view of the above, we are of the opinion that we can rely upon the test results issued by ATIRA vide their report dated 02.08.2018. The test result obtained by appellant from ATI....
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....duct can be bent without fracturing around a cylinder of a diameter 7m or more at temperature between 15C to 30C. Yes 3. products in which the textile fabric is either completely embedded in plastics or entirely coated or covered on both sides with such material, provided that such coating or covering can be seen with the naked eye with no account being taken of any resulting change of colour (Chapter 39); The fabric is not completely embedded in plastic. Yes 4. fabrics partially coated or partially covered with plastics and bearing designs resulting from these treatments (usually Chapters 50 to 55, 58 or 60); It is covered with plastic polymer on one side and bears a design like a dot matrix design resulting from coating process. Yes 5. plates, sheets or strip of cellular plastics, combined with textile fabric, where the textile fabric is present merely for reinforcing purposes (Chapter 39); or The product contains 85% and more cotton. Yes On going through the above details, we find that the product/fabric 'fusible interlining fabric of cotton' of the appellant fulfills all the aforementioned criteria/conditions for being classified under Heading 5903 of the C....
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....ntion that the fabric is partially coated or partially covered with plastics and bears designs resulting from these treatments. The test result also mentions that the said fabric is coated only on one side. On plain reading of the same, we can assume that the said fabric is completely covered or completely coated on one side with plastic polymer and the other side is uncoated. Thus, even when one side of the fabric is completely coated with plastic polymers, it cannot be said to be partially coated or partially covered with plastic polymers. To clarify the issue, we will be required to refer to the meaning of 'partially' as appearing in the dictionaries. The meaning of 'partially' as per various dictionaries is mentioned below: (i) As per Vocabulary.com, meaning of 'partially' is - in part, partly, in some degree. (ii) As per Thesaurus.com, meaning of 'partially' is - partly, somewhat, fractionally, in some measure, On going through the aforementioned meanings of 'partially' appearing in various dictionaries, it can be derived that it stands for 'a small part' of the whole OR 'a small fraction' of the whole OR 'a small measure' of the whole. In the present case, the fabric of....
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....ore than 85% cotton. Also, on going through the various headings covered under Chapter 52 and relying on the theory of elimination, we find that the product of the appellant would not fall under Heading 5201 to 5207 as they do not cover cotton fabric but cover either cotton, cotton waste, cotton sewing thread or cotton yarn. The said product would also not fall under Heading 5210 or 5211 (which covers Woven fabrics of cotton containing less than 85% by weight of cotton). Therefore, the only headings under which the product of the appellant are likely to be covered in Chapter 52 are Headings 5208 and 5209 (which covers Woven fabrics of cotton containing more than 85% by weight of cotton) and Heading 5212 (which covers other woven fabrics of cotton). 13.1 Headings 5208, 5209 and 5212 of Chapter 52 of the Customs Tariff Act, 1975(51 of 1975) read as under: 5208 WOVEN FABRICS OF COTTON, CONTAINING 85% OR MORE BY WEIGHT OF COTTON, WEIGHING NOT MORE THAN 200 G/M2 - Unbleached : 5208 11 -- Plain weave, weighing not more than 100 g/m2 : 5208 12 -- Plain weave, weighing more than 100 g/m2: 5208 13 -- 3-thread or 4-thread twill, including cross twill : 5208 19 -- Oth....
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....ne and the same colour and the weft yarns of which are unbleached, bleached, dyed, grey or coloured a lighter shade of the colour of the warp yarns. 13.3 Since chapter notes of Heading 5208 and 5209 are not available, reference is being made to explanatory notes to HSN with respect to Headings 5208 and 5209 which read as under: Cotton fabrics are produced in great variety and are used, according to their characteristics, for making clothing, household linen, bedspreads, curtains, other furnishing articles etc. The heading does not include: (a) Bandages, medicated or put up for retail sale (heading 30.05) (b) Fabrics of heading 58.01. (c) Terry toweling and similar terry fabrics (heading 58.02). (d) Gauze (heading 58.03). (e) Woven fabrics for technical uses of heading 59.11. 13.4 Since chapter notes of Heading 5212 are not available, reference is being made to explanatory notes to HSN with respect to Headings 5212 which reads as under: This heading covers woven fabrics (as defined in Part(I)(C) of the General Explanatory Note to Section XI) made of cotton yarns. However, it should be noted that it covers only mixed woven fabrics, other than those of the preceding....
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.... side of the fabric surface. (ii) The fabric should be impervious. (iii) It should satisfy the conditions prescribed in Note 2 of Chapter 59. (c) Chapter Note 2(c) was introduced with effect from 01.03.1989 by virtue of which, fusible interlining fabrics became classifiable under Heading 5903 and which read as 'Textile fabrics, partially or discretely coated with plastic (heading no.59.03]', (d) Chapter Note 2(c) was deleted from Chapter 59 with effect from 16.03.1995. (e) The Board vide Circular No.433/66/98-CX.6 dated 27.11.1998 expressed that the omission of the note was neither intended to nor resulted in changing the classification of fusible interlining cloth under Heading 5903 because as per the HSN Explanatory Notes (1996, 2nd edition, page 894) textile fabrics which are spattered by spraying with visible particles of thermoplastic material and are capable of providing a bond to other fabrics or materials up the application of heat and pressure are covered under Chapter Heading 59.03. Classification of such fabrics under Chapter Heading 59.03 may thus be considered as an exception to Chapter Note 2(a) (4) of Chapter 59 according to which fabrics partially coated o....
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....eleted w.e.f. 16.03.1995 and therefore, the position as existed prior to introduction of the said note would be restored. They have also based their decision on the basis of the retest reports of the fabrics of the appellant which clearly indicate that the samples of the impugned fabric have characteristics which would fall within the exclusion (i) to (v) of Chapter Note 2(a) to CETH 59.03 and also the requirement of 'impervious' for the purpose of Board's telex Circular 30.9.88 and Circular No.5/89 will not be satisfied. 16. We, therefore, find, that the Appellate Tribunal of Chennai has decided in favour of M/s. Madura Coats pvt. ltd. on the following main grounds i.e. (i) Chapter Note 2(c) introduced in Chapter 59 w.e.f. 01.03.1989, by virtue of which fusible interlining fabrics came to be classified under Heading 5903 has been omitted w.e.f. 16.03.1995 (ii) Circular No. 433/66/98-CX.6 dated 27.11.1998 which expressed that the omission of the note 2(c) was neither intended to nor resulted in changing the classification of fusible interlining cloth under Heading 5903 was quashed by the High Court of Madras. (iii) 'Fusible Interlining Fabrics of Cotton' were not classifiable unde....
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....ot help in deciding the classification of the applicant's. The fact that CBEC appealed against the Single Bench judgment in 2005 also indicates that it continues defending Circular No. 433/66/98-CX-6 dated 27/11/1998 and has not made any further course correction. Circular No. 433/66/98-CX-6 dated 27/11/1998, therefore, reflects CBEC's view on the classification of fusible interlining cloth as on date.' 16.1 In view of the above, we find that CBEC Circular No. 433/66/98-CX-6 dated 27/11/1998 is relevant even today and has got persuasive value as on date. Further, Chapter Note 2(a)(4) to Chapter 59 says that fabrics partially coated or partially covered with plastics and bearing designs resulting from these treatments are excluded from Heading 5903 and are usually covered in Chapter 50 to 55, 58 or 60, depending on the materials used. At the same time, according to the Explanatory notes to the HSN of Heading 5903 (detailed in para 11.1 above), textile fabrics which are spattered by spraying with visible particles of thermoplastic material and are capable of providing a bond to other fabrics or materials on the application of heat and pressure are classifiable under heading 5903. Al....
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....efore, find that irrespective of the fact as to whether the fabric of the appellant fulfills the criteria for classification under Heading 5903 or otherwise as per exclusion clauses (1) to (5) of Chapter Note 2(a) of Chapter 59, it would still be classified under Heading 5903 only, on account of the Explanatory notes to the HSN, which states that 'textile fabrics which are spattered by spraying with visible particles of thermoplastic material and are capable of providing a bond to other fabrics or materials on the application of heat and pressure are classifiable under heading 5903' read with the grounds mentioned in Circular No. 433/66/98-CX-6 dated 27/11/1998. In view of the above, we find that the product 'fusible interlining fabric of cotton' of the appellant would undoubtedly be classifiable under Heading 5903 of the Customs Tariff Act, 1975 only. 17. We also find that the appellant has relied upon the decision of the order of the Authority of Advance Ruling of Uttarakhand in the case of M/s. Goodswear Fashion pvt.ltd. The ruling in the above case has been based on the testing of the samples of specimen of fabric of the said applicant from NITRA, Uttar Pradesh. The same is no....
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....3/66/98-CX.6 dated 27.11.1998 by the High Court of Madras is one of the major grounds on which the Appellate Tribunal has decided the case in favour of Madura Coats pvt.ltd. by ruling that the impugned goods would not be classified under CETH 59.03. Further, the view and stand of CBEC in respect of Circular No.433/66/98-CX.6 dated 27.11.1998 has been clearly discussed and clarified in detail in the orders of Authority of Advance Ruling, West Bengal as well as that of the Appellate Authority of Advance Ruling, West Bengal in respect of Sadguru Paridhan pvt.ltd. (referred to in para above). We, therefore, find that the GAAR has rightly relied on the aforementioned judgements as they support our contention and endorse the view that fusible interlining fabrics of cotton are classifiable under Heading 5903 of the First Schedule of the Customs Tariff Act, 1975. 18. Having decided the classification of the product 'Fusible interlining fabrics of cotton' of the appellant, we would also like to rely on the following decisions/judgements which support our view. The same are mentioned hereunder: (1) Order No. 33/WBAAR/2019-20 dated 11.11.2019 issued by the West Bengal Advance Ruling Author....