Tariff classification of imported roller bearing parts turns on actual nature on examination, not a competing heading description.

Imported outer rings of roller bearings were classified by reference to their actual nature on examination, not by a competing tariff description that the importer preferred. Because the goods were found to be identifiable parts of roller bearings below 85 mm, Heading 84.62(3) applied and the refund claim failed. The classification was upheld on the examination report, recorded findings, and invoice description, and the departmental classification was affirmed.

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Issues: Whether the imported goods, described as outer rings, were classifiable under Customs Tariff Heading 84.23 as interchangeable parts of machinery or under Heading 84.62(3) as identifiable parts of roller bearings.

Analysis: The goods were examined and found to be outer rings of roller bearings below 85 mm, fitting the description of identifiable parts of roller bearings covered by Chapter Heading 84.62(3) of the Customs Tariff Act, 1975. The appellant did not dispute the factual finding regarding the nature and dimensions of the goods and relied only on a competing tariff description. The classification was upheld on the basis of the examination report, the recorded findings, and the nature of the goods as reflected in the invoice and inspection.

Conclusion: The classification under Heading 84.62(3) was correctly applied and the claim for refund failed.

Final Conclusion: The appeal was rejected and the departmental classification was affirmed.

Ratio Decidendi: Classification of imported goods depends on their actual nature and identifiable description on examination, and not merely on a coincidental fit with another tariff heading.

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