Casting classification turns on recognised manufacturing process; steel shots and grits made by atomising molten metal fall under residuary entry.

Steel shots and grits produced by atomising molten metal in water were held not to be castings because castings ordinarily involve pouring or injecting molten metal into a mould and allowing it to solidify in the required shape. As the manufacturing process here used water jet or centrifugal force to disintegrate molten metal into pellets without a conventional mould or pattern, the goods did not answer the description of Item 26AA. Applying the rule that a residuary tariff entry is used only when goods cannot reasonably fit a specific entry, the products were classified under Item 68.

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Issues: Whether steel shots and grits manufactured by atomising molten metal in water are castings classifiable under Item 26AA of the Central Excise Tariff or fall under the residuary Item 68.

Analysis: The materials placed before the Tribunal showed that castings are ordinarily understood as metallic objects obtained by pouring or injecting molten metal into a mould and allowing it to solidify in the required shape. The process used for steel shots and grits did not involve a conventional mould or pattern; instead, molten metal was disintegrated by a water jet or centrifugal force into pellets which solidified in water. Technical literature and the earlier Tribunal view supported the conclusion that these products were not formed in the manner in which castings are formed. Since the residuary entry can be applied only when the goods cannot reasonably be brought within a specific entry, the proper classification had to be determined on the nature of the manufacturing process and the accepted meaning of castings.

Conclusion: Steel shots and grits are not castings and are not classifiable under Item 26AA; they fall under Item 68, and the appeal succeeds in favour of the Revenue.

Ratio Decidendi: Goods can be taken to the residuary tariff entry only when they do not reasonably answer the description of a specific entry, and articles not produced by the recognised process of casting cannot be classified as castings merely because they emerge from molten metal.

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