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Issues: Whether torch switches manufactured for use in torches are classifiable under Tariff Item 61 of the Schedule to the erstwhile Central Excise Tariff as electric lighting fittings, or under Tariff Item 68 as residuary goods.
Analysis: The classification had to be determined by the common parlance test and the understanding of the goods in the trade. Tariff Item 61 was directed to electric lighting fittings, and the expression "switches, plugs and sockets, all kinds" had to take colour from that principal entry. The evidence showed that torch switches were marketed and understood as parts of torches, not as electric lighting fittings, and the Revenue led no evidence to the contrary. In the absence of any basis to bring such switches within Tariff Item 61, they fell within the residuary entry.
Conclusion: Torch switches are not classifiable under Tariff Item 61 and are classifiable under Tariff Item 68. The issue is answered in favour of the assessee.
Ratio Decidendi: For tariff classification, the common parlance and trade understanding of the goods governs, and words in a specific entry must be read in the context of the principal description; goods not understood as falling within that description are to be classified under the residuary entry.