Excise classification of add-on cards and motherboards requires factual inquiry into nature, use and machine relationship before tariff entry application.

In excise classification disputes involving add-on cards and motherboards, proper classification depends on a factual examination of the goods' nature, character, use and relationship with automatic data processing machines. Where the Tribunal has not undertaken that inquiry before applying tariff entries, the factual foundation is inadequate and the classification issue cannot be decided reliably. The matter must therefore be remitted to the fact-finding authority for fresh consideration in accordance with law after assessing the nature and functions of the goods.

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Issues: Whether the classification dispute concerning add-on cards and motherboards required remand to the Tribunal for fresh consideration after examining the nature, character and function of the goods in relation to automatic data processing machines.

Analysis: The Tribunal had not undertaken a proper factual inquiry into the nature and function of the products before applying the tariff entries. Classification of goods for excise purposes depends upon a detailed appreciation of their character, use and relationship with the machine in question. Where the factual foundation is inadequate and the core classification issue has not been examined with due care, the proper course is to remit the matter for reconsideration by the fact-finding authority.

Conclusion: The matter was required to be remanded to the Tribunal for a fresh decision in accordance with law after considering the nature and functions of the goods.

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