Tariff classification turns on ordinary commercial meaning, and specialised refractory support anchors fell outside Heading 73.30.

Imported stainless steel anchors used to support refractory lining in a pressure vessel were held classifiable under Heading 73.33/40, not Heading 73.30. The tariff entry was construed according to its ordinary commercial meaning and customs trade usage, and Heading 73.30 was confined to anchors of the kind used for mooring ships or similar purposes. Because the goods were specialised fittings for refractory support and not anchors in that ordinary sense, and no material supported classification under Chapter 84, the departmental classification was sustained and the appeal failed.

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Issues: Whether imported stainless steel anchors used for refractory lining of a pressure vessel were classifiable under Heading 73.30 as anchors and parts thereof of iron or steel, or under Heading 73.33/40 as other articles of steel.

Analysis: The classification had to be determined by the meaning of the tariff entry as understood in common parlance and in customs trade usage. Heading 73.30 was confined to anchors of the kind used for mooring ships and similar purposes, and the explanatory notes supported that restricted meaning. The imported goods were not anchors in that ordinary sense but specialised items used for supporting refractory bricks in a boiler. The fact that they were made of stainless steel also mattered because the heading relied on by the appellants did not cover such articles in the relevant tariff structure. The note in Section XV and Rule 3(a) did not assist the appellants because the dispute turned on the proper interpretation of the heading itself. In the absence of any material to support classification under Chapter 84, the department's classification under Heading 73.33/40 was upheld.

Conclusion: The claim for classification under Heading 73.30 failed, and the departmental classification under Heading 73.33/40 was correct.

Final Conclusion: The appeal was rejected and the revenue's classification was sustained.

Ratio Decidendi: A tariff heading must be construed according to its ordinary commercial meaning, and where the entry is confined to a specific class of goods, specialised articles not answering that ordinary description cannot be brought within it merely because they bear a similar name.

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