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Issues Involved:
Classification of Aluminium Rolled Products and Iron and Steel Sections. Detailed Analysis: 1. Aluminium Rolled Products: The appellant claimed the classification of Aluminium Rolled Products under Tariff sub-heading 7604.29, asserting that these products are rolled profiles of base metal aluminium and should be classified as such. The Department, however, assessed these products under Tariff sub-heading 8302.41, which pertains to base metal mountings, fittings, and similar articles suitable for buildings. The appellant argued that the imported goods are not ready-to-use products for panels or walls but require further operations to be made suitable for such uses. They relied on the Supreme Court's judgment in Dunlop India Ltd. v. U.O.I., which states that classification should be based on the goods as presented at the time of import, not their end-use. The Department countered that the goods were colour-coated, fabricated, and designed for ready fitting, thus falling under the category of mountings and fittings suitable for buildings. The Tribunal found that the goods, having assumed the characteristics of identifiable components of ceiling panels, would be covered under Tariff Heading 8302.50, which includes brackets and similar fixtures for walls and ceilings. The Tribunal noted that the Explanatory Notes and the specific design and fabrication of the goods indicated their suitability for a specific purpose, thus justifying their classification under 8302.50 rather than 7604.29. 2. Iron and Steel Sections: The appellant claimed classification under Tariff sub-heading 7301.20, which covers angles, shapes, and sections of iron or steel. The Department assessed these products under Tariff sub-heading 8302.41, arguing that they were specifically designed and fabricated for use in venetian blinds. The appellant contended that these sections required further processing before being used as components of venetian blinds, thus should be classified under the general heading for iron and steel sections. The Department emphasized that the goods were colour-coated, fabricated, and pressed at specific angles, making them suitable for direct use in venetian blinds. The lower appellate authority noted that the goods had assumed the characteristics of identifiable parts of venetian blinds and were sold as such in the market. The Tribunal upheld the Department's classification, stating that the suitability for use in venetian blinds was a necessary ingredient for classification under Tariff Heading 83.02. The Tribunal referred to Chapter Note 1(a) and (b) of Chapter 76, which indicates that aluminium bars, rods, and profiles would be classified under Chapter 76 only if they had not assumed the character of articles or products of other headings. Given the specific design and fabrication, the goods were correctly classified under 8302.41. Conclusion: The Tribunal concluded that both Aluminium Rolled Products and Iron and Steel Sections were correctly classified under Tariff Heading 83.02, specifically under sub-headings 8302.50 and 8302.41, respectively. The appeals were rejected, affirming the Department's assessment.
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