Tariff classification of iron flats used for Rehri and Tonga wheels turns on trade understanding, not mere shape.

Iron channels manufactured from iron flats and used as Rehri/Tonga wheel parts were held classifiable under Item 68 of the Central Excise Tariff, not Item 26AA(ia), because the goods were not known in trade as channels and were cleared as wheel parts. The Tribunal applied the earlier decision on the same manufacturing process, trade understanding and ISI specification, holding that shape alone does not determine tariff classification unless the goods satisfy the trade and functional characteristics of channels.

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Issues: Whether iron channels manufactured from iron flats and used in Rehri/Tonga wheels were classifiable under Item 26AA(ia) of the erstwhile Central Excise Tariff or under Item 68 of the Central Excise Tariff.

Analysis: The disputed goods were identical to those considered in an earlier Tribunal decision dealing with the same manufacturing process, trade understanding, and ISI specification. The prior decision had held that the goods were not known in trade as channels and were cleared as wheel parts for Tonga or Rehri. Mere shape did not make them channels for tariff purposes unless they satisfied the trade understanding and functional characteristics of channels.

Conclusion: The goods were correctly classifiable under Item 68 of the Central Excise Tariff and not under Item 26AA(ia). The appeal succeeded.

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