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Issues: Whether M.S. bends, reducers and similar goods used to connect two lengths of pipes laid at angles are classifiable as pipes and tubes under Heading 7305.90 or as pipe fittings under Heading 7307.
Analysis: The goods were found to be manufactured by welding cut pipe pieces into bends or reducers meant to join two straight lengths of pipes and to withstand water pressure at the joint. The HSN description of pipe fittings specifically covers elbows, bends, reducers and similar articles used for connecting the bores of two tubes together. The ISI reference described the goods only as specials and did not equate them with pipes. On their function and commercial character, the goods were held not to be pipes and tubes but articles used to connect pipes.
Conclusion: The goods are classifiable as pipe fittings under Heading 7307 and not under Heading 7305.90, therefore the classification adopted by the lower authority was upheld.
Ratio Decidendi: Articles manufactured and used as joints or connectors between straight lengths of pipes are classifiable as pipe fittings when their essential function is to connect pipe bores rather than to serve as pipes themselves.