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Issues: Whether throw-away inserts manufactured from sintered carbides were classifiable under Tariff Item 51A(iii) as tools designed to be fitted into hand tools or machine tools, or under Tariff Item 62 as tool tips in any form or size.
Analysis: The decisive test was the essential character of the goods, not merely their market name, detachable nature, or the difference in the mode of fixing. The goods were unmounted, made of sintered carbides of metals such as tungsten, molybdenum and vanadium, and were used for machining metal. Their multiple edges, shorter life span, and clamping method did not alter their basic character or function. On the materials found by the departmental authorities and the Tribunal, throw-away inserts were only a detachable variety of tool tips. The wide language of Tariff Item 62 covered such goods, and the trade-parlance material relied upon by the assessee was insufficient to exclude them from that specific entry.
Conclusion: The goods were correctly classified under Tariff Item 62 and not under Tariff Item 51A(iii).
Ratio Decidendi: Where competing tariff entries are in issue, classification turns on the goods' essential character, function and use, and a specific entry in wide terms prevails over a more general entry notwithstanding differences in market name, form, fixing method or life span.