Electric pressure cooker classification: treated as a pressure cooker where external current heats the element for cooking.

An electric pressure cooker was held to answer the description of a pressure cooker for classification under Item 54 of the Central Excise Tariff. The fitted electric element was treated as only the means of generating heat, while the operative heat source was the electric current supplied from outside. The objection that the cooker lacked an external heat source was rejected because the current entered from an external source and heated the element for cooking. On that basis, the goods fell within the specific tariff entry, and the alternative tariff claims did not require examination.

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Issues: Whether an electric pressure cooker is classifiable under Item 54 of the Central Excise Tariff as a pressure cooker.

Analysis: The electric element fitted inside the cooker was treated only as the means by which heat was generated, while the real heat source was the electric current supplied from outside. Since the current enters from an external source and heats the element for cooking, the objection that the cooker lacked an external heat source was rejected. On that basis, the goods answered the description of pressure cooker under the specific tariff item, and the alternative claims under other tariff entries did not require examination.

Conclusion: The electric pressure cooker was correctly classifiable under Item 54 of the Central Excise Tariff, and the appeal succeeded.

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