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Issues: Whether forged steel grinding media balls were classifiable under Tariff Item 7208 or, in view of Chapter Note 6 to Chapter 84, under the residuary Tariff Item 7308.
Analysis: The classification had to be determined by the tariff structure and the relevant chapter notes. Although the goods had earlier been treated as roughly shaped forged items under the old tariff, the introduction of Chapter Note 6 required that steel balls be classified either under Chapter 84 or under Chapter 73. Since the goods did not fall within Chapter 84, they necessarily attracted Chapter 73. The attempt to treat them as forged items under the old classification was rejected because earlier treatment could not override the express chapter note. Reliance on a Board Circular was also unavailing, as it had not been relied upon below and in any event did not deal with the goods in question or with Chapter Note 6.
Conclusion: The balls were correctly classified under Tariff Item 7308 and not under Tariff Item 7208; the challenge to the classification failed.