Customs classification of transmission spare parts upheld under vehicle heading, not engine-parts heading, for special purpose fire tenders.

Imported spare parts described as transmission-related components were held not to be parts of engines or motors merely because they performed a transmission function. As they were not themselves engine parts, they were classified as parts of special purpose motor vehicles, namely fire tenders, under Heading 87.03 rather than Heading 84.63. The Tribunal therefore upheld the lower authority's classification in favour of the Revenue and sustained the reassessment.

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Issues: Whether the imported spare parts described as transmission-related components were classifiable under Heading 84.63 as parts of engines and motors, or under Heading 87.03 as parts of special purpose motor vehicles, namely fire tenders.

Analysis: The goods were described as canter shaft splined, sleeve main shaft gear, clutch main shaft slinger, gear main shaft low and bushing main shaft gear. The Tribunal held that although the items may serve a transmission function, they were not parts of an engine. On that footing, they were to be treated as parts of special purpose motor vehicles and not brought within Heading 84.63. The classification adopted by the lower authority was therefore found to be correct.

Conclusion: The goods were correctly classified under Heading 87.03 and not under Heading 84.63; the classification in favour of the Revenue was upheld.

Final Conclusion: The challenge to the reassessment failed and the impugned classification was sustained.

Ratio Decidendi: Spare parts of special purpose motor vehicles are not classifiable under the heading for parts of engines and motors unless they are themselves parts of the engine; otherwise they fall to be classified with the vehicle to which they belong.

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