Lubricating oil classification turns on ordinary use and primary function, not a shift to residuary tariff treatment.

Refrigeration compressor oil was held to fall within the specific lubricating-oil entry because it satisfied the chemical criteria for sub-heading 2710.60 and was ordinarily used to lubricate pistons, rotors and bearings in compressors. Technical literature and Indian Standard Specification I.S. 4578-1968 supported that primary lubricating function, and no contrary material displaced those findings. A product covered by the specific lubricating-oil heading cannot be moved to the residuary sub-heading merely because it is suited to a particular end use.

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Issues: Whether refrigeration compressor oil is classifiable as lubricating oil under sub-heading 2710.60 or as a residual product under sub-heading 2710.99.

Analysis: Sub-heading 2710.60 covers lubricating oil, that is to say, any oil ordinarily used for lubrication, excluding hydrocarbon oil with flash point below 94 C. The product was found to satisfy the chemical criteria for the lubricating oil entry, and the evidence on record showed that its primary function in refrigeration compressors was to lubricate pistons, rotors and bearings. The technical literature and Indian Standard Specification I.S. 4578-1968 also confirmed that refrigeration oil is primarily meant for lubrication. No material was brought by the Revenue to dislodge those findings. A product answerable to the specific lubricating-oil entry could not be shifted to the residuary heading merely because it was suited to a particular end-use.

Conclusion: The oil was correctly classifiable under sub-heading 2710.60 and not under sub-heading 2710.99, and the Revenue's appeal failed.

Ratio Decidendi: Where a product is ordinarily used for lubrication and its primary function is to lubricate compressor parts, it falls under the specific lubricating-oil heading and cannot be classified under a residuary entry.

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