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Issues: Whether the imported footwear were classifiable as sports footwear under Chapter Note 64 of the Customs Tariff Act, 1975, or as ordinary footwear under the claimed tariff heading.
Analysis: Sports footwear under Chapter Note 64 are footwear specially designed for sporting activity and having, or having provision for, the attachment of spikes, springs, stops, clips, bars or the like. The samples showed no such attachments or provision for attachment. The opinion obtained from the Footwear Design and Development Institute also stated that the footwear did not have special features to enhance sports activity or improve sports performance. On these facts, the imported footwear did not satisfy the tariff description of sports footwear.
Conclusion: The classification under sports footwear was incorrect and the footwear were not liable to be treated as sports footwear.
Ratio Decidendi: Footwear cannot be classified as sports footwear unless it is specially designed for sporting activity and has, or has provision for, the specified attachments or equivalent sports-enhancing features.