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Issues: Whether the imported calibration source was classifiable under Heading No. 85.14 as resistance heated furnaces and ovens or under Heading No. 85.43 as electrical machines and apparatus having individual functions not specified or included elsewhere in Chapter 85.
Analysis: The goods were imported for testing and precise calibration of industrial radiation thermometers and were described in the catalogue and invoice as a calibration source with a highly uniform temperature source. The record did not describe the goods as a furnace or oven, and their essential use was not heating but providing a uniform temperature along the cavity. The explanatory notes to Heading 85.14 concerned induction or dielectric heating equipment used mainly for heat treatment, which did not match the nature or purpose of the imported goods. Heading 85.43, being of wider residuary scope, covered apparatus not more specifically included elsewhere in Chapter 85, and the goods fitted that description.
Conclusion: The goods were correctly classifiable under Heading No. 85.43 and not under Heading No. 85.14, and the Revenue's appeal succeeded.