Commercial classification of specialised motor vehicle fasteners depends on trade identity, not technical description.

Tariff classification of motor vehicle fasteners turns on their commercial identity, not their scientific description. Goods such as bolts, nuts, U-bolts and U-clamps were treated as automobile parts because they were specially designed, sold under part numbers, used only in specific vehicles, and supplied as original equipment or replacement parts to manufacturers and dealers. There was no evidence that they were known in the market as general-purpose nuts and bolts. Mere possible use as fasteners did not alter their predominant character. Accordingly, the items were classified as parts of automobiles under Tariff Item 68 rather than as nuts and bolts under Tariff Item 52.

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Issues: Whether the goods manufactured by the assessee, described as motor vehicle parts such as bolts, nuts, U-bolts, U-clamps and similar items, were classifiable under Tariff Item 52 as nuts and bolts or under Tariff Item 68 as parts of automobiles.

Analysis: Classification had to be determined by the popular or commercial understanding of the goods and not by their scientific or technical description. The evidence showed that the items were specially designed, sold under part numbers, used only in specific motor vehicles, and supplied as original equipment or replacement parts to automobile manufacturers and dealers. There was no material to show that the goods were known in the market or used in common parlance as general-purpose nuts and bolts. Mere stray or possible use as fasteners did not change their essential character as automobile parts.

Conclusion: The goods were correctly treated as parts of automobiles and not as general nuts and bolts. Classification under Tariff Item 68 was upheld, and the Revenue's challenge failed.

Ratio Decidendi: For tariff classification, the decisive test is the commercial or popular sense in which the goods are known to persons dealing with them, and specialised goods retain their character as parts of a machine when that is their predominant identity in trade and use.

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