Tariff classification of specially made motorcycle components depends on their true commercial character, not merely their end use.

Specially manufactured articles for motorcycle assembly were held to be classifiable by their true commercial description rather than by their end use alone. Although the goods resembled bolts, nuts and rods and were made to specification for incorporation in motorcycles, the tariff enquiry focused on whether they were ordinary fasteners under Item 52 or integral motor-vehicle components under Item 34A. Construing the tariff entries and the exemption for motor-vehicle parts and accessories not otherwise specified, the court treated the articles as parts and accessories of motor vehicles, not as ordinary bolts and nuts. The exemption under Notification No. 99/71 was therefore available.

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Issues: Whether the articles manufactured for use in motorcycle assembly were classifiable as bolts and nuts under Item 52 of the Central Excise Tariff or as parts and accessories of motor vehicles eligible for exemption under Notification No. 99/71.

Analysis: The decisive enquiry was the true description of the goods for tariff purposes. The process by which the articles were manufactured and the fact that they were put to a specific end use in the manufacturer's motorcycles did not by itself control classification. The articles were special types of bolts, nuts and rods made to specification and drawing for incorporation in motorcycles, and their broad commercial character had to be examined in the context of the tariff entries and the exemption notification. On a reasonable construction of Item 34A and Item 52, and having regard to the scope of the exemption for motor-vehicle parts and accessories not otherwise specified, the articles were found to be integral component parts of motorcycles rather than ordinary bolts and nuts attracting Item 52.

Conclusion: The articles fell under Item 34A as parts and accessories of motor vehicles and not under Item 52; the assessee was entitled to the exemption.

Ratio Decidendi: For tariff classification, the broad description of the article in the tariff entry is controlling, and goods specially manufactured as integral parts of motor vehicles may be classified as parts and accessories notwithstanding their resemblance to ordinary nuts and bolts or their specific end use.

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