Goods classification under the Tariff depends on essential character; aerobridges were held classifiable as machinery, not metal structures.

Imported aerobridges were treated as sophisticated machines with electrical, electronic and hydraulic components, not as mere iron or steel structures. Heading 7308 was held to cover complete or incomplete metal structures and parts of structures fixed in position, whereas Chapter 84 applies to machinery and mechanical appliances. Applying the tariff scheme and the goods' essential character, classification under heading 7308 was found inconsistent with the Tariff. The aerobridge was therefore classifiable under heading 8428, in favour of the assessee.

---

---

Issues: Whether imported aerobridges were classifiable under heading 7308 as bridges and bridge-sections of iron or steel, or under heading 8428 as lifting, handling, loading or unloading machinery.

Analysis: The aerobridge was held to be a sophisticated machine with electrical, electronic and hydraulic components, and not a simple iron or steel structure. Heading 7308 was found to cover complete or incomplete metal structures and parts of structures made from metal members, which are generally fixed in position and do not include machinery or a prime mover. The tariff scheme was also relied upon: Chapter 73 covers articles of iron and steel, while Chapter 84 in Section XVI covers machinery and mechanical appliances, showing that the two headings operate in different fields. On that basis, the classification adopted by the customs authorities was found inconsistent with the scheme of the Tariff.

Conclusion: The aerobridge was not classifiable under heading 7308 and was held classifiable under heading 8428, in favour of the assessee.

Ratio Decidendi: A goods classification must follow the tariff scheme and the essential character of the goods; a sophisticated machine with mechanical, electrical or hydraulic components cannot be treated as a mere metal structure or bridge-section.

---