Trade parlance controls tariff classification of starter armatures, and the Revenue must prove the specific entry claimed.

Tariff classification of starter armatures for automotive starter motors turned on trade parlance: the market treated starter motors and their parts as automobile ancillaries, not as parts of electric motors. The excise authorities produced no material to show that starter armatures were regarded in trade as electric motor parts, and the trade certificates filed by the manufacturer were not rebutted. On that basis, the burden of proving classification under Item 30, sub-item (4) was not discharged, and the goods were accepted as falling outside that entry; the respondents' classification was upheld.

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Issues: Whether starter armatures manufactured for automotive starter motors were classifiable under Item 30, sub-item (4) as parts of electric motors, or under Tariff Item 34A as parts and accessories of motor vehicles not otherwise specified.

Analysis: The decisive test in tariff classification was the meaning attributed to the goods in trade parlance. The material on record showed that the trade treated starter motors and their parts as automobile ancillaries and not as electric motors. The excise authorities produced no material to establish that starter armatures were regarded in the market as parts of electric motors. In the absence of rebuttal to the trade certificates produced by the manufacturer, the burden of proving the suggested classification under Item 30, sub-item (4) was not discharged.

Conclusion: The starter armatures were not shown to be parts of electric motors and were not classifiable under Item 30, sub-item (4); the respondents' classification was accepted.

Final Conclusion: The appeal failed and the classification adopted by the respondents was upheld.

Ratio Decidendi: In tariff classification of excisable goods, trade parlance governs, and the burden lies on the Revenue to prove that the goods fall within the specific tariff entry relied upon.

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