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Issues: Whether special switchboard pilot wire relays imported by the assessee were classifiable under Heading 85.18/27(1) or under Heading 85.18/27(3) of the Customs Tariff Act.
Analysis: The goods were shown, on the printed literature and the surrounding evidence, to be designed for feeder circuits much above 400 volts. Classification could not be determined merely by the current ratings of the current transformers or the voltage of the pilots. The controlling consideration was the intended function of the relays and the higher-voltage system for which they were designed. The classification notice and the earlier tribunal view supported placing relays used for such higher-voltage protection within the lower sub-heading meant for protective or control circuits of the relevant ratings.
Conclusion: The goods were correctly classifiable under Heading 85.18/27(3), and the assessee's claim succeeded.
Final Conclusion: The assessment under the higher classification was set aside and the assessee obtained the consequential relief flowing from classification under the appropriate tariff heading.
Ratio Decidendi: For tariff classification of electrical relays, the decisive test is the designed function and intended use of the goods in the relevant electrical system, not merely isolated input ratings such as current transformer or pilot voltage.