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Issues: Whether switches manufactured for use in air-conditioning systems were classifiable under sub-heading 8536.10 as relays for refrigerating and air-conditioning appliances, or under sub-heading 8536.90 as other electrical apparatus.
Analysis: Heading 85.36 covers electrical apparatus for switching or protecting electrical circuits, including switches and relays. Sub-heading 8536.10 is confined to specified relays, particularly overload protection or thermal relays, starting relays and control relays for refrigerating and air-conditioning appliances. The record did not contain evidence to show that the goods manufactured by the respondent, though called switches, were in substance relays. In the absence of proof that the goods fell within the specific description in sub-heading 8536.10, they remained classifiable under the residuary sub-heading 8536.90.
Conclusion: The goods were held classifiable under sub-heading 8536.90 and not under sub-heading 8536.10, and the Revenue's appeal failed.
Ratio Decidendi: Where tariff classification is claimed under a specific sub-heading, the party asserting that classification must establish that the goods strictly answer the specific description; absent such proof, the goods fall under the appropriate residuary entry.