Tariff classification turns on essential description and function; tailor-made items still fall under the specific customs heading.

Imported goods were classified by reference to the broad description and essential function of the tariff headings, not by their trade description or the fact that they were specially manufactured. The disputed 40 items were found to match the specific tariff descriptions, so they could not be treated as component parts of machinery under the claimed heading merely because they were tailor-made or not commonly known in the market as nuts, bolts, screws, or pins. The customs classification was therefore upheld against the assessee.

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Issues: Whether the imported items were classifiable as component parts of machinery under the claimed tariff heading or as goods falling under the specific headings applied by customs.

Analysis: The items were examined not by their common trade description or by the fact that they were specially manufactured, but by whether they answered the broad description and essential function of the relevant tariff headings. The finding of fact recorded below was that the disputed 40 items matched the specific tariff descriptions and therefore could not be treated as goods classifiable under the claimed heading merely because they were tailor-made or not commonly known as nuts, bolts, screws, or pins in the market.

Conclusion: The classification adopted by the customs authorities was upheld against the assessee.

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