Commercial identity governs tariff classification of doctors' cases; external similarity to brief-cases did not exclude the residuary entry.

For tariff classification, commercial identity and intended use controlled the classification of doctors' cases. Although they resembled brief-cases externally, they were specially designed with internal fittings for medical equipment and were not understood in trade as brief-cases or other specified travel goods. As they did not answer the description in Tariff Item 48A, classification properly fell to the residuary entry under Tariff Item 68, and the assessee's classification was sustained.

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Issues: Whether doctors' cases were classifiable under Tariff Item 48A as travel goods, brief cases or vanity cases, or under Tariff Item 68 as a residuary entry.

Analysis: The item, though resembling a brief-case externally, was designed and constructed with internal cavities and fittings for carrying medical equipment. It was specially meant for doctors and not for carrying papers, briefs or documents, which are the normal attributes of a brief-case. In commercial and trade understanding, doctors' cases were not regarded as brief-cases. Tariff Item 48A covered only specified travel goods, and the item did not answer that description. Since it was neither a brief-case nor a specified travel good, classification could only fall under the residuary entry.

Conclusion: The doctors' cases were not classifiable under Tariff Item 48A and were correctly classified under Tariff Item 68, in favour of the assessee.

Final Conclusion: The appeal failed and the classification in the residuary tariff entry was sustained.

Ratio Decidendi: For tariff classification, the commercial identity and intended use of the goods govern, and an article that is not understood in trade as a specified item cannot be placed in that specific entry merely because of external similarity; it then falls to the residuary entry.

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