S.C.AGRAWAL, J.

(1) THE only question that falls for consideration in these appeals is whether inner tube valves imported by the appellants in connection with the manufacture of tubes for tyres are classifiable under sub-heading (1) of Heading 84.61 of the Customs Tariff as claimed by the Revenue or under sub-heading (2) of Heading 84.61 as claimed by the appellants. Heading 84.61 of the Customs Tariff reads as under:

"TAPS, cocks, valves and similar appliances for pipes, boiler, shells, tanks, vats and the like, including pressure-reducing valves and thermostatically-controlled valves. (1) Not elsewhere specified. (2) Isolating valves, non-return valves, safety valves, pressure-reducing valves, exhaust-relief valves, thermostatically-controlled valves, solenoid-operated valves, valves made of corrosion-resisting material such as stainless steel, nickel monel, incoloy, hastelloy and other valves lined with rubber or other corrosion-resisting materials; steam traps."

(2) THE valves are made of copper alloy and the appellants have produced certificates of the manufacturers in support of their claim that the valves were made of corrosion-resisting mate