Base metal ammunition boxes classified as containers of base metal, excluding the general iron or steel heading.

Ammunition boxes made of base metal, used for keeping and conveying ammunition, were treated as containers of base metal under Heading 8312.90. The more general Heading 7308.90 for other articles of iron or steel was excluded because a specific tariff entry governed the goods. As the boxes did not fall within narrower sub-headings under Heading 83.12, classification under 8312.90 was upheld and the duty demand founded on that entry was sustained against the assessee.

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Issues: Whether ammunition boxes made of base metal were classifiable under Heading 7308.90 as other articles of iron or steel, or under Heading 8312.90 as other containers of base metal.

Analysis: The boxes were used for keeping and conveying ammunition and were admittedly made of base metal. Heading 83.12 covered containers of base metal, while Heading 73.08 applied to other articles of iron or steel only where no more specific heading covered the goods. As the goods were containers of base metal and did not fall within the narrower sub-headings under Heading 83.12, they were appropriately classified under sub-heading 8312.90. The demand based on the higher classification was therefore founded on the correct tariff entry.

Conclusion: The classification under Heading 8312.90 was upheld and the appeals were rejected against the assessee.

Final Conclusion: The impugned orders confirming the duty demand on the basis of classification under Heading 8312.90 were sustained.

Ratio Decidendi: Where goods are specifically covered as containers of base metal under a tariff heading, classification under a more general heading for other articles of iron or steel is excluded.

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