Tariff classification follows the dominant actual function of goods, and mechanical use can control over electrical character.

Tariff classification of frequency transducers turned on their actual function in the relevant use. Although the goods operated on electrical principles and were general-purpose electrical devices, they were used mainly for measuring differential pressure and other mechanical purposes. The dominant operative function was therefore treated as essentially mechanical rather than as an electrical measuring or controlling function. On that basis, classification under Item 90.28(4) of the Customs Tariff Act, 1975 was accepted, with the claimed refund, reclassification, and consequential relief following.

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Issues: Whether frequency transducers imported for use in ferrodynamic instruments were classifiable under Item 90.28(4) of the Customs Tariff Act, 1975 or under Item 90.24(1) or Item 90.28(1).

Analysis: The transducer was found to be a general purpose electrical device used to convert one form of energy into another, but in the facts of the case its use was mainly connected with measuring differential pressure and other mechanical purposes. Though the article operated on electrical principles, its function in the relevant use was held to be essentially mechanical rather than an electrical measuring or controlling function. On that basis, the classification under Item 90.28(4) was held to be appropriate.

Conclusion: The transducers were correctly classifiable under Item 90.28(4), and the assessee was entitled to the claimed relief.

Final Conclusion: The appeal succeeded and the refund and reclassification claim was accepted with consequential relief.

Ratio Decidendi: For tariff classification, the decisive consideration is the actual function for which the goods are used in the relevant facts, and an electrical device may be classified according to its operative mechanical use where that use is the dominant one.

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