Predominant industrial use governs classification: engine components for diesel engines were not treated as motor-vehicle parts.

Valves, pistons, piston rings and similar components imported for industrial diesel engines were not chargeable to countervailing duty as motor-vehicle parts because the relevant test was the predominant use of the engines for which they were intended. As the engines were mainly used in shovels, cranes, oil drilling rigs, generator sets and compressors, they retained a non-vehicular industrial character, and did not become motor-vehicle parts merely because some were also fitted to dumpers. The components therefore followed the character of the engines and were outside the motor-vehicle parts classification for countervailing duty purposes.

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Issues: Whether valves, pistons, piston rings and similar components imported for manufacture of industrial diesel engines were chargeable to countervailing duty as parts of motor vehicles.

Analysis: The applicable test was whether the engines for which the components were imported were of vehicular type or were predominantly used for non-vehicular industrial applications. Since the engines were principally used in shovels, cranes, oil drilling rigs, generator sets and compressors, their character could not be treated as that of motor-vehicle parts merely because a smaller portion was fitted to dumpers. On the same reasoning, the components of such engines could not be classified as parts of motor vehicles for countervailing duty purposes.

Conclusion: The components were not chargeable to countervailing duty as applicable to motor vehicle parts, and the appeal succeeded.

Ratio Decidendi: Goods intended for and predominantly used in non-vehicular industrial applications do not acquire the character of motor-vehicle parts for the purpose of countervailing duty merely because they may incidentally be fitted to vehicles.

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