H.R. Syiem, Member (T)

1. The material in dispute in all these appeals is an article that the department calls a steel plate but which the importers call a mould. The department holds that these steel sheets would be assessable under Chapter 73 as plates of iron or steel, hot-rolled, or cold-rolled, whereas the assessees argued that Chapter 84 is the correct heading for it, because this is a mould and is a part of machinery. The goods that were imported were described variously by the different importers as stainless steel sheets or as flat moulds. At other times, they were described in invoices as stainless steel press plates; they have also been described simply as press plates. However, there is no need to record all the different names which these articles have been given, because one fact is uncontradicted and this is that the goods are flat rectangular pieces of stainless steel whose technical description can be given thus: 2.5 mm thickness, 3110 x 1270 mm length and width, made of martensitic steel, hardness 40-45 Rockwell C and used in forming or shaping or pressing plastic laminates and laminated sheets. The ground of dissension between the Custom House and the importe