Integral parts of metal containers classified under parent heading, not as packing accessories, under customs tariff rules.

Metal tops, bottoms and lids made specifically for metal containers were treated as integral parts of the containers, not as packing accessories. Applying Note 1 of Chapter 83, parts of base metal are classified with the parent article, while Note 2 of Section XV excludes only parts of general use. Because these goods were neither parts of general use nor detachable accessories, they were classifiable with the metal containers themselves under Heading 8312.12. The classification under Heading 83.09 was rejected, and the Revenue's view was upheld against the assessee.

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Issues: Whether metal tops, bottoms and lids manufactured for metal containers were classifiable as packing accessories under Heading 83.09 or as parts of metal containers under Heading 8312.12.

Analysis: The goods were manufactured specifically for metal containers and were essential to make the containers complete. Under Note 1 of Chapter 83, parts of base metal are classified with their parent articles, and Note 2 of Section XV excludes only parts of general use. The tops, bottoms and lids did not answer the description of parts of general use or packing accessories; instead, they formed an integral part of the containers. On that basis, the classification adopted by the Revenue was upheld.

Conclusion: The goods were correctly classifiable under Heading 8312.12 and not under Heading 83.09, against the assessee.

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