Commercial parlance governs customs classification of tungsten filaments; unfinished parts were assessed as base metals, not lamp components.

Imported tungsten filaments were held not to be classifiable as electric filament lamps or identifiable parts or components of such lamps under Tariff Item No. 85.18/27(4), because they were only filament parts requiring further processing before they could function as lamp components. In the absence of a clear statutory criterion, commercial parlance governed the classification exercise, and the goods did not answer the higher-duty description. They were therefore assessable under Heading No. 81.01.01/04(1) as base metals and articles thereof, and the classification challenge failed.

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Issues: Whether imported tungsten filaments were classifiable under Tariff Item No. 85.18/27(4) of the Indian Customs Tariff Act, 1975 as electric filament lamps or identifiable parts or components thereof, or under Heading No. 81.01.01/04(1) as base metals and articles thereof.

Analysis: The imported goods were filament parts requiring further processing before they could function as a component of an electric lamp. They were not shown to answer the description of electric filament lamps, nor to be identifiable parts or components of such lamps for the higher-duty entry. In the absence of a clear statutory criterion, the meaning understood in commercial parlance was held to govern the classification exercise.

Conclusion: The goods did not fall under Tariff Item No. 85.18/27(4) and were rightly assessable under Heading No. 81.01.01/04(1). The classification challenge failed.

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