Tariff classification of sewing machine parts turns on intended industrial use, not a broader departmental reading of domestic machine entries.

Imported sewing machine components described in the licence, import documents and departmental circular as parts for industrial machines could not be classified as parts of domestic sewing machines. The tariff scheme distinguished domestic sewing machines from the residuary category, and the record supported the finding that the hooks were intended for industrial use and would not suit domestic machine speeds. Because the revenue did not discharge the burden of proving the specific domestic sewing machine entry, broader departmental views of use could not justify reclassification. The revisional interference with the reasoned classification and refund order was therefore unsustainable.

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Issues: Whether the imported components of sewing machines were classifiable as parts for domestic sewing machines or under the residuary tariff entry for other sewing machines, and whether the Government of India rightly exercised revisional power to disturb the Appellate Collector's classification and refund order.

Analysis: The tariff entry drew a clear distinction between the specific category of domestic sewing machines and the general residuary category. The appellant's licence, import documents, and the departmental circular all described the goods as components for industrial sewing machines, and the circular itself indicated that sewing machines operated by motors of 1/4 H.P. or more fell outside the scope of domestic sewing machines. The record also supported the Appellate Collector's finding that the imported hooks were meant for industrial machines and would not withstand the speed of domestic machines. On these facts, the burden on the revenue to justify classification under the domestic sewing machine entry was not discharged, and the revisional order was based on an erroneous interference with a reasoned factual finding.

Conclusion: The imported goods were not classifiable as components for domestic sewing machines, and the Government of India's revisional order was unsustainable.

Ratio Decidendi: Where the record and contemporaneous import documents show that the goods are intended for industrial sewing machines, they cannot be reclassified as parts of domestic sewing machines merely on a broader departmental view of use, especially when the revenue fails to prove the specific tariff entry invoked.

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