Tariff classification by true nature and function upheld for one component, while gasket classification was sustained for the other item.

Tariff classification must follow the true nature and function of the imported goods: a Pneumatic Power Cylinder, not being an independent machine, was treated as a component part of the air-control apparatus and classified under the claimed heading. The Dual Cup Gasket Assembly was not shown to be anything other than a gasket, and Chapter Note 2(a) of Chapter 90 supported the classification adopted for that item. The classification dispute therefore succeeded only in respect of Item No. 5 and failed in respect of Item No. 6, with relief limited to the item found to have been wrongly classified.

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Issues: Whether the imported Pneumatic Power Cylinder and Dual Cup Gasket Assembly were correctly classified under the Customs Tariff headings applied by the lower authority.

Analysis: The Pneumatic Power Cylinder was found not to be an independent machine and was accepted as a component part of the air-control apparatus, warranting classification under the claimed heading. In contrast, the appellants failed to establish that the Dual Cup Gasket Assembly was not a gasket. The reasoning also relied on Chapter Note 2(a) of Chapter 90 in support of the classification adopted for that item.

Conclusion: The appeal succeeded in respect of Item No. 5 and failed in respect of Item No. 6.

Final Conclusion: The classification dispute was resolved partly in favour of the appellants, with consequential relief granted only for the item accepted as wrongly classified.

Ratio Decidendi: For tariff purposes, goods are to be classified according to their true nature and function; a component that is not an independent machine may be classified with the apparatus of which it forms part, while the party challenging a classification must establish that the adopted heading is incorrect.

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