Tariff classification of thrust bearing assemblies must follow the specific heading for bearing assemblies, not general bearing or pump-part headings.

Thrust bearing assemblies used in P.D. pumps were held to fall under Heading 84.83 as bearing assemblies, not under Heading 84.82 as ball or roller bearings or under Heading 84.13 as pump parts. The analysis applied Chapter Note 2 of Section XVI, requiring classification by the specific tariff heading first, and relied on the Heading 84.82 text and HSN notes to reject the department's view that machinery parts incorporating bearings could be treated as bearings themselves. Because the assemblies were separately classifiable as bearing assemblies, the demand and penalty based on the alternative classification were set aside.

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Issues: Whether thrust bearing assemblies used in P.D. pumps were classifiable under Heading 84.82 as ball or roller bearings, under Heading 84.83 as bearing assemblies, or under Heading 84.13 as parts of pumps, and whether the demand and penalty could survive on that classification.

Analysis: Chapter Note 2 of Section XVI required classification of parts first by the specific headings in Chapters 84 and 85, and only thereafter by the residuary rule for other parts. The Heading 84.82 text and the HSN notes relied on by the department excluded machinery parts incorporating ball, roller or needle roller bearings from Heading 84.82 and indicated that bearing housings and similar parts were covered elsewhere. The assemblies in question were not bearings per se but bearing assemblies fitted in pumps, and therefore could not be forced into Heading 84.82. They also could not be classified as pump parts under Heading 84.13 when they were separately classifiable as bearing assemblies under Heading 84.83.

Conclusion: The thrust bearing assemblies were classifiable under Heading 84.83 and not under Heading 84.82 or Heading 84.13. The classification adopted by the department was rejected, and the demand and penalty were set aside.

Final Conclusion: The assessee succeeded on the central classification question, with consequential relief from the duty demand and penalty.

Ratio Decidendi: A machine part that is separately classifiable under a specific tariff heading must be classified there, and a bearing assembly incorporating bearings is not classifiable as ball or roller bearings merely because it performs a bearing function.

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