Tariff classification turns on functional character, with numbering machines classified under the specific heading for such goods.

Imported automatic numbering machines were classified by reference to their essential description and functional character, not the material used in manufacture. The explanatory note to Heading 84.43 did not support treatment as printing machinery because the goods were specifically identifiable as hand-operated self-changing numbering stamps. On that basis, the goods fell under Customs Tariff Heading 96.11 for numbering machines, and classification under Heading 8443.60 was rejected.

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Issues: Whether the imported automatic numbering machine was classifiable under Customs Tariff Heading 8443.60 as printing machinery or under Customs Tariff Heading 96.11 as numbering machines.

Analysis: The imported goods were found to be numbering machines, specifically hand-operated self-changing numbering stamps. Classification was held to depend on the description and character of the goods, not on the material from which they were made. The claim that the goods were printing machinery was rejected, and the explanatory note to Heading 84.43 was applied to support classification under Heading 96.11.

Conclusion: The goods were correctly classifiable under Customs Tariff Heading 96.11 and not under Customs Tariff Heading 8443.60, against the assessee.

Final Conclusion: The appellate challenge to the classification failed and the departmental classification was sustained.

Ratio Decidendi: For tariff classification, the essential description and functional character of the imported goods prevail over the material used in their manufacture, and goods specifically identifiable as numbering machines are classifiable under the heading applicable to such machines.

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