Tariff classification must turn on the scope of the heading first, not merely the goods' constituent material.

Tariff classification must be determined by the true scope of the relevant heading and not by an invariable reliance on the constituent material of the goods. Where the threshold question is whether transmission lines or cables are "apparatus" at all, that issue must be decided first before any resort to a base-metal heading under Section XV. The Court found the Tribunal's reasoning cursory because it had rejected classification under Heading 85.48 without adequately examining the applicability of Section Note 1(f) of Section XV. The dispute was remitted for fresh determination of the classification issue and the connected objection regarding consistency with the show-cause notice.

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Issues: Whether the Tribunal was in rejecting classification of the appellant's goods under Tariff Heading 85.48 on the basis that transmission lines were not apparatus, and in proceeding to classify the goods under Chapter XV without first determining the applicability of Section Note 1(f) of Section XV.

Analysis: The Tribunal's conclusion that transmission cables could not be treated as machinery or apparatus was held to be cursory and unsupported by reasons. The Court stated that classification cannot be decided by applying an invariable test based only on the constituent material of the goods. The proper inquiry was whether transmission lines could be regarded as apparatus at all, because if they were apparatus, the question would arise whether the goods manufactured by the appellant were electrical parts of such apparatus under Tariff Heading 85.48. The Court also left open the appellant's contention that the Department could not adopt a stand contrary to the show-cause notice, and directed that the dispute be decided together with the meaning and scope of Tariff Heading 85.48.

Conclusion: The Tribunal's order was set aside and the matter was sent back for fresh decision on the classification dispute and connected objections.

Ratio Decidendi: Classification under the tariff must turn on the proper scope of the relevant heading and not merely on the constituent material of the goods; where the very character of the equipment as an apparatus is in dispute, that question must be determined first before resorting to a base-metal heading.

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