The court ruling discusses the correct interpretation of the notes, chapters, and general rules of interpretation in classifying goods under the Central Excise Tariff Act. The court holds that classification should be in consonance with the terms of the headings and relevant chapter notes, and the heading providing a more specific description should be preferred over the general one. The court emphasizes that the application of the rules must follow the interpretive instructions, and notes that the revenue’s argument to classify the goods based on their principal or sole use is insubstantial. The court also gives an example of a similar case where the item fell within a specific description rather than the general one.

The court held that Note 1(m) to Chapter 85 excludes “articles of Chapter 90,” and General Note 3(a) states that headings that are specifically provided should be preferred over general ones. The court also explained that Note 2 of Chapter 85 only applies to parts that act as accessories and not to independent articles. The court concluded that the goods in question should be classified under Chapter 90, and not Chapter 85.

decided by the Supreme Court of India on 29.03.23


Sanjiv Narang Adv. is an Advocate on Record in the Supreme Court of India. His qualifications include an LLB from University of Delhi and a Masters degree in Personnel Management from Panjab University,Chandigarh.In his more than 3 decades of experience, he has practiced law at the District, High Court and Supreme Court levels.He also has more than a decade of experience in the field of Management. He is the author of two books namely Laws for Women in India and Innovation, Why What and How.