Commercial identity governs tariff classification; functional similarity alone cannot shift goods to a different heading without trade evidence.

Tariff classification of a shaft and bearing assembly depended on its commercial identity, not merely on functional similarity. The Revenue had to prove by evidence that the goods were known in trade as transmission shafts under Tariff Heading 84.83, and no such evidence was produced. Prior approval of classification as fan parts further supported the assessee's position. The goods were therefore not classifiable as transmission shafts and were accepted as parts of an industrial fan under sub-heading 8414.99, with consequential relief following.

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Issues: Whether the goods described as shaft and bearing assembly were classifiable under Tariff Heading 84.83 as transmission shafts or under Tariff sub-heading 8414.99 as a part of an industrial fan.

Analysis: For tariff classification, the burden lay on the Revenue to establish that the goods were known in trade as the article described in the tariff entry. No evidence was produced to show that shaft and bearing assembly was known in the market as a transmission shaft. Mere similarity of function was insufficient to equate two different commodities, and the prior approval of the classification of the goods as fan parts supported the assessee's claim.

Conclusion: The goods were not classifiable under Tariff Heading 84.83 and the assessee's classification as a fan part was accepted.

Final Conclusion: The appeal succeeded and the assessee obtained consequential relief.

Ratio Decidendi: In tariff classification, goods are to be identified according to their commercial or trade understanding, and similarity of function alone does not justify classification under a different tariff entry unless the Revenue proves that understanding by evidence.

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