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Issues: Whether the imported goods could be uniformly classified under Customs Tariff Heading 8207 by applying Note 2 to Chapter 82, or whether the goods had to be assessed on their individual character and use.
Analysis: The imported consignments comprised a mixed assortment of goods, including complete dies, jigs, fixtures, checking fixtures, inspection jigs and other items, and a substantial portion was meant for captive consumption rather than for manufacture of tools and dies for supply under the purchase order relied upon by the Department. Note 2 to Chapter 82 applies to parts of base metal of articles of that chapter, but it does not justify a blanket classification of all imported items under the same heading. Goods that are separately identifiable under the tariff must be classified according to their own nature and description, and only those items that are specifically identifiable as unclassified parts of base metal can fall under Heading 8207.
Conclusion: The uniform reclassification of all goods under Heading 8207 was unsustainable. The goods required individual classification on their own merits, and the matter had to be reconsidered by the adjudicating authority.