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Issues: Whether the imported magnetic buttons for handbags and leather goods were correctly classifiable under Heading 9606 of the Customs Tariff Act, 1975, or under Heading 8308 of the Customs Tariff Act, 1975.
Analysis: The goods were described in the manufacturer's catalogue as magnetic buttons for handbags, pouches and similar articles, and were admittedly used in leather bags. The relevant HSN Explanatory Notes to Heading 8308 cover clasps and fasteners for handbags, purses and similar articles, which matched the function of the imported goods when fixed to the bags. By contrast, Heading 9606 covered buttons of the pierced and shank type used for underwear, outer garments, footwear and similar purposes, and there was no evidence that the imported goods belonged to that category. On this basis, Heading 8308 was the more appropriate classification.
Conclusion: The goods were held classifiable under Heading 8308 and not under Heading 9606, and the Revenue's appeal succeeded.
Ratio Decidendi: Where an imported article is used as a clasp or fastener for leather goods, its tariff classification depends on its functional identity as reflected in the HSN Explanatory Notes, and it cannot be classified as a button under Heading 9606 unless evidence shows it is of the relevant button category.