Tariff classification of motor vehicle switches depends on function and trade identity, not lighting entry wording.

Automotive switches used in motor vehicles were assessed for classification under Central Excise Tariff Item 61 as electric lighting fittings or under Item 68 as residuary goods. Applying common parlance, commercial parlance, and functional character tests, the switches were held not to be lighting fittings: the horn and dipper switch was not a lighting switch, the combination switch served multiple vehicle functions, and the flasher switch indicated direction rather than providing illumination. The broader language of Customs tariff headings did not alter this result, and departmental trade advice was treated as non-binding. The goods were therefore classifiable under Item 68 rather than Item 61.

---

---

Issues: Whether automotive switches used in motor vehicles, namely flasher switch, horn and dipper switch, and combination switch, were classifiable under Central Excise Tariff Item No. 61 as electric lighting fittings or under Central Excise Tariff Item No. 68.

Analysis: Central Excise Tariff Item No. 61 covered electric lighting fittings and, on its language, required the switch to be one used for lighting or illumination. The impugned goods were motor vehicle parts and, by their function and commercial identity, were not known or dealt with as electric lighting switches. The horn and dipper switch was not a lighting switch at all, the combination switch was a multi-purpose switch for several vehicle functions and not merely a lighting switch, and the flasher switch only indicated direction and did not provide illumination in the relevant sense. Applying the common parlance and commercial parlance tests, and looking to the functional character of the goods, the switches fell outside Item No. 61. They were also not displaced by the broader language of the Customs tariff headings. The departmental trade advice was noted but was not binding.

Conclusion: The goods were not classifiable under Central Excise Tariff Item No. 61 and were correctly classifiable under Central Excise Tariff Item No. 68, in favour of the assessee.

Final Conclusion: The appeal succeeded on the classification issue, and the impugned switches were held to fall under the residuary tariff item rather than the electric lighting fittings entry.

Ratio Decidendi: For tariff classification, goods must be understood by their primary function and by their identity in trade and common parlance, and an entry describing electric lighting fittings cannot extend to motor vehicle switches that are not primarily lighting or illumination switches.

---