Locomotive parts classification: tailor-made control components used in a locomotive fall under Heading 86.07, not Heading 90.32.

Goods specially designed for use in a locomotive, including sensors, panels, modules, circuit breakers, relays and switches, were treated as locomotive parts rather than independent automatic regulating or controlling instruments. The analysis applied the HSN Explanatory Notes and the scope of Heading 90.32, which covers automatic regulating or controlling apparatus, and concluded that tailor-made components fitted at various points in a locomotive do not meet that description. The goods were therefore classified under Heading 86.07 as parts of railway locomotives, and the importer's classification was upheld.

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Issues: Whether the imported locomotive control system and related components were classifiable under Heading 90.32 as automatic regulating or controlling instruments and apparatus, or under Heading 86.07 as parts of railway locomotives.

Analysis: The product literature and HSN Explanatory Notes were examined. Heading 90.32 covers instruments and apparatus for automatic regulation or control, including certain regulating devices for electrical or non-electrical quantities. The goods in question were tailor-made for use in a locomotive and consisted of sensors, panels, modules, circuit breakers, relays, and switches fitted at various points in the locomotive. On that basis, they were not treated as independent instruments or apparatus for automatic regulating or controlling, but as components intended for use as locomotive parts.

Conclusion: The goods were correctly classifiable as parts of locomotives under Heading 86.07 and not under Heading 90.32.

Final Conclusion: The classification adopted in favour of the importer was upheld and the Revenue's appeal failed.

Ratio Decidendi: Goods specially designed for and used as components of a locomotive are classifiable as locomotive parts when they do not themselves constitute independent automatic regulating or controlling instruments or apparatus.

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