Corrosion-resistant valve classification upheld where catalogue reading showed Platnam-covered parts brought the goods within the tariff heading.

Imported valves were treated as classifiable under Heading 84.61(2) where the catalogue showed that the valves, discs and seats were made of Platnam, a corrosion-resistant alloy. The description had to be read as a whole, together with the standard cast iron and cast steel stop valve entries, so the corrosion-resistant reference extended to the inner portions exposed to corrosive fluid. The valve was not excluded from the heading merely because all external parts were not corrosion-resistant. The earlier view was incorrect because it isolated the reference to discs and seats and ignored the reference to valves; the goods were therefore correctly classifiable under Heading 84.61(2).

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Issues: Whether the imported valve was correctly classifiable under Heading 84.61(2) of the Customs Tariff Act, 1975 as a valve wholly made of, or lined with, corrosion resistance material.

Analysis: The catalogue showed that the valves, discs and seats were made of Platnam, a corrosion-resistant alloy, and it had to be read with the description of standard cast iron and cast steel stop valves. On that reading, the reference to Platnam covered the inner portion of the valve that comes into contact with corrosive fluid, and it was not realistic to treat the valve as outside the corrosion-resistant category merely because every external part was not so made. The earlier authority had misread the catalogue by isolating the reference to discs and seats and ignoring the reference to valves.

Conclusion: The goods were correctly classifiable under Heading 84.61(2), in favour of the assessee.

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