Functional tariff classification controls where imported goods are specially adapted as essential machinery components, not ordinary fabrics.

Imported silk bolting cloth specially cut for fitting into machinery used in abrasive manufacture was classified by functional character rather than a strained alternative use. The Court held that its realistic commercial identity was that of an essential component part of machinery, so Item 72(3) of the Import Tariff applied and the classification as silk fabrics under Item 48(c) was not sustainable. The decision confirms that tariff entry selection must reflect the true nature, design, and practical use of the goods, not an unreal or commercial misfit classification.

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Issues: Whether the imported silk bolting cloth was classifiable as a component part of machinery under Item 72(3) of the First Schedule to the Import Tariff or as silk fabrics under Item 48(c).

Analysis: The cloth was imported in standardised cut sizes for fitting into specially designed machinery used in the manufacture of abrasives. Its use as a wearing fabric was found to be unrealistic, and the suggested alternative uses did not displace its character as an essential component of machinery. The Court held that the customs authorities had adopted an interpretation of Item 48(c) that was not supported by reasonable commercial or practical understanding, whereas the petitioner's classification under Item 72(3) was consistent with the nature and use of the goods.

Conclusion: The goods were held to fall under Item 72(3), and the higher assessment under Item 48(c) was not sustainable; the writ petition succeeded in favour of the assessee.

Ratio Decidendi: Where imported goods are specially adapted and commercially identified as essential component parts of machinery, tariff classification must follow their true functional character and not an unreal or strained alternative classification.

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