Tariff classification principles require specific headings and parts of general use to prevail over machine-specific descriptions.

Tariff classification turned on whether goods specifically covered by a chapter heading or treated as parts of general use could be moved to a machine-specific heading. A water flow controller, being an appliance regulating fluid flow, was held classifiable under Heading 84.81 because goods expressly covered by Chapter 84 remain there even if specialised for a particular machine. Manifold and flanges were held classifiable under Heading 73.07 as parts of general use, and therefore excluded from Chapter 84. The assessee's classification was rejected, the departmental view was upheld, and the appeal was dismissed.

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Issues: (i) Whether water flow controller was classifiable under Heading 84.81 or as a part of blast furnace under Heading 84.17; (ii) whether manifold and flanges were classifiable under Heading 73.07 as parts of general use or under Heading 84.17.

Issue (i): Whether water flow controller was classifiable under Heading 84.81 or as a part of blast furnace under Heading 84.17.

Analysis: Note 2(a) to Section XVI requires goods which are themselves included in a heading of Chapter 84 to be classified under that heading. Heading 84.81 covers taps, cocks, valves and similar appliances used to regulate the flow or pressure of fluids, and the Explanatory Notes state that such goods remain in the heading even if specialised for use on a particular machine or apparatus. Since the product regulated fluid flow, it fell within Heading 84.81.

Conclusion: The water flow controller was correctly classifiable under Heading 84.81 and not under Heading 84.17.

Issue (ii): Whether manifold and flanges were classifiable under Heading 73.07 as parts of general use or under Heading 84.17.

Analysis: Note 1(g) to Section XVI excludes parts of general use of base metal from Chapters 84 and 85. The tariff specifically treats articles of Heading 73.07 as parts of general use. As manifold and flanges answered that description, they could not be classified as parts of blast furnace under Heading 84.17.

Conclusion: Manifold and flanges were correctly classifiable under Heading 73.07 and not under Heading 84.17.

Final Conclusion: The tariff classification claimed by the assessee was rejected and the departmental classification was upheld, resulting in dismissal of the appeal.

Ratio Decidendi: Where a product is specifically covered by a tariff heading or is treated as a part of general use, it must be classified accordingly and cannot be shifted to a more general or machine-specific heading merely because of its specialised application.

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