Strict tariff definition controls classification of rolled stainless steel pattis, excluding them from strip classification.

Stainless steel pattis manufactured by rolling were examined for tariff classification under the competing entries for rough-shaped pieces and strips. The article states that the goods were irregular in shape and size, had uneven thickness, and were neither supplied in coil form nor in flattened coil form. Because the tariff definition of strip required approximately rectangular cross-section, mill-rolled, trimmed or sheared edges, and supply in coil or flattened coil form, the definition was applied strictly and the goods did not meet its essential characteristics. The pattis were therefore classifiable under Tariff Item 25(8), not as strips under Tariff Item 25(12)(1).

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Issues: Whether the stainless steel pattis manufactured by rolling were classifiable under Tariff Item 25(8) as pieces roughly shaped by rolling or under Tariff Item 25(12)(1) as strips.

Analysis: The goods were found to be of irregular shape and size with uneven thickness and were neither supplied in coil form nor in flattened coil form. The tariff definition of strip required hot or cold rolled products in approximately rectangular cross-section, with mill-rolled, trimmed or sheared edges, and supply in coil or flattened coil form. The tariff description and definition were held to control classification, and the relevant notes and definitions had to be applied strictly. On that basis, the goods did not satisfy the definition of strip.

Conclusion: The goods were not strips under Tariff Item 25(12)(1) and were classifiable under Tariff Item 25(8); the Revenue's appeals failed.

Final Conclusion: The classification adopted by the appellate authority was upheld, and the Revenue was not entitled to reclassify the goods as strips.

Ratio Decidendi: Where a tariff entry contains a specific definition, classification must follow that definition strictly, and goods not answering the essential characteristics of the defined entry cannot be placed within it.

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