Specific tariff heading controls classification of centrifugal pumps used in air-conditioning and power plant systems.

Centrifugal pumps used in air-conditioning systems and power plants were held classifiable under Heading 8413 as pumps for liquids, because the goods were themselves specifically covered by that heading. Their use in circulating water for air-conditioning or cooling systems did not make them parts of air-conditioning machines under Heading 8415, and their use in power plants did not place them under Heading 8410, particularly where the turbines involved were steam turbines rather than hydraulic turbines. Applying Section Note 2(a) to Section XVI, a specifically described article remains classified in its own tariff heading even if designed for use with another machine, so the contrary duty, penalty and interest demands could not survive.

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Issues: (i) Whether centrifugal pumps cleared by the assessee for use in air-conditioning systems and power plants were classifiable under Heading 8413 as pumps for liquids, or under Heading 8415 as parts of air-conditioning machines or under Heading 8410 as parts of turbines.

Analysis: The pumps were manufactured as centrifugal pumps for liquids and were capable of use in several applications, including water supply, irrigation, cooling and air-conditioning systems. A pump used merely to circulate water in an air-conditioning plant does not become a part of an air-conditioning machine, because the heading for air-conditioning machines covers the machine as such and not every component used in a circulating system. Likewise, a pump used for cooling or water circulation in a power plant does not become a part of a hydraulic turbine, particularly when the turbines involved are steam turbines and not hydraulic turbines. Under Section Note 2(a) to Section XVI, an article which is itself covered by a specific heading is to be classified in that heading even if it is specially designed to work as part of another machine. Heading 8413 specifically covers pumps for liquids, including centrifugal pumps.

Conclusion: The pumps were correctly classifiable under Heading 8413, and not under Headings 8415 or 8410; the demand of duty, penalty and interest based on the contrary classification could not survive.

Final Conclusion: The appeal succeeded and the assessee obtained relief against the classification adopted by the department, with all consequential monetary demands set aside.

Ratio Decidendi: Where a product is itself covered by a specific tariff heading, it must be classified in that heading even if it is used as a component or accessory of another machine, and such use does not shift it to the heading of the larger machine.

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