Motor vehicle body parts are classifiable as parts and accessories, not complete bodies, where the assembly is incomplete.

Front end structures for motor vehicles, consisting of a bonnet cover, windscreen and dashboard panel fitted to a chassis, were held to fall under Chapter Heading 8708 as parts and accessories, not under Chapter Heading 8707 as complete bodies. The tariff scheme, read with the Customs Tariff entry and HSN notes, distinguishes complete bodies and cabs from parts of bodies and incomplete body assemblies that do not yet have the character of complete bodies. On that basis, the reclassification demand failed and relief was available to the assessee.

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Issues: Whether the front end structure manufactured by the assessee was classifiable under Chapter Heading 8707 as bodies for motor vehicles or under Chapter Heading 8708 as parts and accessories of motor vehicles.

Analysis: The front end structure consisted of a bonnet cover, windscreen and dashboard panel fitted to the chassis. Chapter Heading 8707 covers bodies, including cabs, whereas Chapter Heading 8708 covers parts and accessories of motor vehicles. The structure of the tariff, read with the corresponding Customs Tariff entry and the HSN notes, showed that parts of bodies and incomplete body assemblies not yet having the character of complete bodies fall under the heading for parts and accessories, not under the heading for bodies.

Conclusion: The front end structure was correctly classifiable under Chapter Heading 8708 and not under Chapter Heading 8707.

Final Conclusion: The demand based on reclassification failed, and the assessee was entitled to relief.

Ratio Decidendi: Parts of motor vehicle bodies, and assemblies lacking the character of complete bodies, are classifiable under the heading for parts and accessories of motor vehicles rather than under the heading for bodies themselves.

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