Classification of specially designed agricultural implement parts turns on sole or primary use, not fastener form, under the tariff test.

Specially designed kit and parts for use in agricultural implements attached to tractors were classifiable by reference to their design, purpose and actual use. The governing test was whether the goods were suitable solely or primarily for the relevant tariff heading; on that basis, the parts were treated as agricultural implement components rather than as threaded fasteners. HSN notes were treated as persuasive only and could not displace the settled classification test where inconsistent with it. The goods were therefore classified under Heading 84.32 and not under Heading 73.18.

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Issues: Whether the disputed kit and parts, designed specifically for use in agricultural implements attached to tractors, were classifiable under Heading 84.32 as parts of agricultural implements or under Heading 73.18 as fasteners.

Analysis: The decisive consideration was the design, purpose and actual use of the goods. The goods were found to be specially designed parts for agricultural implements and not merely threaded fasteners. The classification principle relied upon required examination of whether the goods were suitable solely or primarily for the relevant chapter heading. Applying that approach, and treating the HSN notes as persuasive rather than controlling where they conflict with the settled legal test, the goods were found to belong to the agricultural implements heading and not to the fasteners heading.

Conclusion: The disputed parts were correctly classifiable under Heading 84.32 and not under Heading 73.18, in favour of the assessee.

Ratio Decidendi: For classification of specially designed parts, the governing test is their sole or primary suitability and use; where goods are designed and used as parts of agricultural implements, they are classifiable accordingly, and persuasive HSN notes cannot override the controlling legal test.

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