Tariff classification depends on the goods' true commercial and functional description under the correct customs heading.

Imported motor rollers used in the manufacture of screens were treated as electro forming moulds, and on that admitted functional description they were classified under Heading 84.60 of the Customs Tariff Act, 1975 rather than Heading 84.40 or 84.59. The classification turned on matching the tariff entry to the goods' commercial and functional description on the facts, not on the earlier or alternate assessments. The result was that the correct heading governed the relief flowing from the revised tariff treatment.

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Issues: Whether the imported motor rollers were correctly classifiable under Heading 84.60 of the Customs Tariff Act, 1975, rather than under Heading 84.40 or Heading 84.59 of the Customs Tariff Act, 1975.

Analysis: The goods were imported for manufacture of screens, and both sides ultimately agreed that they were electro forming moulds. On that basis, the goods were held to answer the description covered by Heading 84.60. The earlier assessment and the later change in classification under other headings did not survive this conclusion.

Conclusion: The goods were held classifiable under Heading 84.60 of the Customs Tariff Act, 1975 and not under Heading 84.40 or Heading 84.59.

Final Conclusion: The appeal succeeded and the appellants obtained the resulting relief flowing from the correct tariff classification.

Ratio Decidendi: For tariff classification, imported goods must be placed under the heading that accurately answers their commercial and functional description as found on the admitted facts.

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