Classification of iron and steel flats: simple cutting and notching did not create a new commodity or shift goods out of Tariff Item 26AA(ia).

Mere cutting, trimming, notching, or removal of burrs from iron and steel flats does not amount to manufacture of a new and distinct commodity. Two way keys and cotters made by cutting flats into lengths and shaping them without machining, polishing, or grinding remained identifiable as cut pieces of flats and stayed within Tariff Item 26AA(ia). Tariff Item 68 applied only where additional processing such as machining, polishing, or grinding produced a different commodity. On the facts found, the goods were correctly classifiable under Tariff Item 26AA(ia), and the Revenue's appeals failed.

---

---

Issues: Whether two way keys and cotters manufactured from iron and steel flats were classifiable under Tariff Item 26AA(ia) or Tariff Item 68, and whether the processes undertaken amounted to manufacture of a new commodity.

Analysis: The relevant process for two way keys was cutting flats into predetermined lengths and grinding the cut ends to remove burrs. For cotters, the flats were cut lengthwise and breadthwise and notched to obtain cut pieces of flats. These operations did not involve machining, polishing or grinding of the kind contemplated for shifting the goods out of Tariff Item 26AA(ia). The circular issued by the Board also treated such goods as falling under Tariff Item 26AA(ia), while indicating Tariff Item 68 only where additional processes such as machining, polishing or grinding were undertaken. On the facts found, the products remained identifiable as cut pieces of flats and did not emerge as a new and distinct commodity.

Conclusion: The goods were correctly classifiable under Tariff Item 26AA(ia) and not under Tariff Item 68. The Revenue's appeals were without merit.

Ratio Decidendi: Mere cutting, trimming, notching, or removal of burrs from iron and steel flats, without further machining, polishing, or grinding, does not amount to manufacture of a new commodity and does not take the goods out of Tariff Item 26AA(ia).

---