Trade understanding governs tariff classification of zinc callots, which were treated as zinc manufactures rather than strips.

Where a tariff item does not specifically define the product, classification must follow its commercial identity and trade understanding. Zinc callots punched from zinc strips were treated as distinct from strips, sheets, or circles, and were sold to battery manufacturers as callots rather than as strips. They were therefore classifiable as zinc manufactures not otherwise specified under Tariff Item 68, not under Tariff Item 26B, and the assessee's challenge failed.

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Issues: Whether zinc callots punched from zinc strips and used for dry battery cells are classifiable under Tariff Item 26B of the Central Excise Tariff or under Tariff Item 68.

Analysis: The product was examined according to its commercial sense and trade understanding, since it was not defined in the tariff in a manner that covered it as strips. The material showed that callots are known in international nomenclature as blanks prepared for impact extrusion or forging, and are distinct from sheet, strip, or circle products. The product punched from zinc strips was sold to dry battery manufacturers as callots, not as strips, and was not included within sub-item (2) of Item 26B.

Conclusion: The goods were held to be classifiable as zinc manufactures not otherwise specified under Tariff Item 68, and not under Tariff Item 26B; the assessee's challenge failed.

Final Conclusion: The revision was dismissed and the classification adopted by the excise authorities was left undisturbed.

Ratio Decidendi: Where a product is not specifically defined in the tariff, its classification is to be determined according to its commercial identity and the sense in which it is understood in the trade.

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