Tariff classification of spray control valves turns on functional description and technical literature, supporting pressure reducing valve treatment.

Imported spray control valves and related components were held to fall under Heading 84.61(2) as pressure reducing valves, because the catalogue, technical write-up, and prior classification orders consistently showed that the goods functioned to control steam temperature through feed-water injection. The alternative classification under Heading 84-61(1) was rejected, as the record did not support the appellant's contrary claim. The governing principle is that tariff classification must follow the actual functional description and corroborating technical material of the goods, especially where prior orders support the same classification.

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Issues: Whether the imported spray control valves and components, including seal rings and plugs, were classifiable under Heading 84.61(2) as pressure reducing valves rather than under Heading 84-61(1).

Analysis: The catalogue and write-up produced with the goods described their function as pressure reducing valves used to control steam temperature by injecting feed water through a special valve system. The earlier Government of India order and the Tribunal's prior order in the appellant's own case supported the same classification. On the material on record, the finding that the evidence did not support the appellant's claim could not be sustained.

Conclusion: The valves were correctly classifiable under Heading 84.61(2), and the assessee succeeded on this issue.

Ratio Decidendi: Where the functional description, technical literature, and prior classification orders consistently show that the imported goods operate as pressure reducing valves, they must be classified under the tariff heading applicable to that function rather than under a broader alternative heading.

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