Tariff classification of mirror-finished steel sheets turns on functional use, not appearance, and supports machinery heading treatment.

Stainless steel sheet with both sides mirror finished was examined for tariff classification under Heading 73.15(2) or Heading 84.59(2) of the Customs Tariff Act. The governing test was functional character, not mere form or finish: the goods were treated as akin to press plates and, on the record, there was no material to show they were meant to function as moulds; they were instead used as parts in a hydraulic press for manufacturing laminates. On that basis, the goods were held not classifiable under Heading 73.15(2) and were correctly classifiable under Heading 84.59(2), with the lower authority's classification set aside.

---

---

Issues: Whether stainless steel sheet both sides mirror finished was classifiable under Heading 73.15(2) of the Customs Tariff Act, 1975 or under Heading 84.59(2) of the Customs Tariff Act, 1975.

Analysis: The goods were identical to press plates earlier considered by the Tribunal in related matters. The governing approach was that mere form or finish was not decisive; the real question was whether the article functioned as a mould or as a part of machinery. Earlier orders had held such press plates to fall outside Heading 73.15 and to merit classification under the relevant machinery heading. In the present case, no material was produced to show that the imported goods were meant to function as moulds, and the record supported their treatment as parts used in a hydraulic press for manufacturing laminates.

Conclusion: The goods were not classifiable under Heading 73.15(2) and were correctly classifiable under Heading 84.59(2); the classification adopted by the lower authority was set aside in favour of the assessee.

---