Classification of rotor cutters as cutting tools prevailed where invoice and entry showed separate goods and tariff notes excluded Chapter 84.

Imported rotor cutters were treated as separate goods from the milling machine because the bill of entry and invoice listed them separately with distinct values. Section Note 1(ij) to Section XVI was applied to exclude Chapter 82 goods from classification under Chapter 84, and Heading 82.05 was identified as the specific heading for cutting tools. On that basis, the cutters were classified under Heading 82.05 rather than Heading 85.45/48, and the customs classification was upheld with no relief to the appellant.

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Issues: Whether the imported cutters for rotor were classifiable under Heading 85.45/48 of the Customs Tariff Act or under Heading 82.05, and whether the section note to Section XVI permitted classification under Chapter 84.

Analysis: The Bill of Entry and invoice showed the milling machine and the cutters as separate items with separate values. Section Note 1(ij) to Section XVI made it clear that goods classifiable under Chapter 82 could not be classified under Chapter 84. Heading 82.05 specifically covered cutting tools.

Conclusion: The cutters were correctly classified under Heading 82.05 and not under Heading 85.45/48. The appeal failed.

Final Conclusion: The classification adopted by the customs authorities was upheld and the appellant obtained no relief.

Ratio Decidendi: Where the invoice and entry show the machine and the cutters as separate goods, and the tariff note excludes Chapter 82 goods from Chapter 84, the cutters must be classified under the specific cutting-tools heading.

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