Tariff classification follows the specific heading, and intended use does not override classification of air motors or hydraulic cylinders.

Tariff classification must follow the specific Central Excise Tariff entry for the product, and special adaptation or intended use in a particular machine does not displace that classification. Air motors were held classifiable under Heading 8412 because Chapter Note 2(a) required parts falling within a specific Chapter 84 heading to be classified there, and end-use was not decisive where the heading itself covered the goods. Hydraulic cylinders were classified under Heading 8431 because they were not shown to fall within Heading 8412 as engines or motors, and the tariff did not specifically place them in Heading 8412.

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Issues: (i) Whether air motors manufactured by the appellant were classifiable under Heading 8412 of the Central Excise Tariff rather than under Heading 8431 on the basis of their intended use in the appellant's machinery. (ii) Whether hydraulic cylinders manufactured by the appellant were classifiable under Heading 8431 of the Central Excise Tariff.

Issue (i): Whether air motors manufactured by the appellant were classifiable under Heading 8412 of the Central Excise Tariff rather than under Heading 8431 on the basis of their intended use in the appellant's machinery.

Analysis: The applicable classification had to be determined under the Central Excise Tariff, not by reference to the Customs Tariff entries. Chapter Note 2(a) of Chapter 84 required parts falling within a specific heading of Chapter 84 to be classified in that heading, and the end-use of the article was not decisive where the tariff heading itself covered the goods. The fact that the motors were specially adapted for the appellant's machinery did not take them out of Heading 8412.

Conclusion: The air motors were classifiable under Heading 8412 and not under Heading 8431, in favour of the assessee.

Issue (ii): Whether hydraulic cylinders manufactured by the appellant were classifiable under Heading 8431 of the Central Excise Tariff.

Analysis: Heading 8412 of the Central Excise Tariff covered engines and motors, while the tariff entry did not include hydraulic cylinders as such. No material was shown to establish that the hydraulic cylinder could be treated as an engine or motor under Heading 8412. In that setting, the item fell outside Heading 8412 and was correctly placed under Heading 8431.

Conclusion: The hydraulic cylinders were correctly classified under Heading 8431, against the assessee.

Final Conclusion: The classification dispute was resolved item-wise, with air motors falling under Heading 8412 and hydraulic cylinders remaining under Heading 8431.

Ratio Decidendi: Where a tariff entry specifically covers the product, classification must follow that entry and the mere fact of special adaptation or intended use in a particular machine does not displace the tariff-based classification.

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