Principal function controls tariff classification of composite machines; vehicle washer pumps fall under the pump heading, not use-based classification.

Reciprocating pumps manufactured as vehicle washers were held to be classifiable by their principal function as pumps under Heading 84.13, rather than under Heading 84.24 based on end use. Board circulars and tariff guidance supported classification of power driven pump sets under Heading 84.13, and the principle applied was that composite machines must be classified according to the component or function giving them their essential character. Mere deployment of the pump for a particular use did not justify changing its tariff heading. The classification under Heading 84.24 was therefore rejected, and Heading 84.13 was accepted.

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Issues: Whether reciprocating pumps manufactured as vehicle washers were classifiable under Heading 84.13 as pumps or under Heading 84.24 on the basis of their use.

Analysis: The item was found to function principally as a pump. The relevant board circulars and tariff guidance treated power driven pump sets as classifiable under Heading 84.13, and applied the principle that composite machines are to be classified according to the component or function that gives them their principal character. The classification could not be altered merely because the pump was put to a particular use.

Conclusion: The goods were classifiable under Heading 84.13, and the classification under Heading 84.24 was incorrect, in favour of the assessee.

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