Integrated machinery classification: truck-mounted drilling rig treated as self-propelled boring machine, defeating rival vehicle classification.

Imported truck-mounted drilling rig was classifiable as a self-propelled boring or sinking machine under Heading 84.30, not as a special purpose motor vehicle under Heading 87.05, because the chassis, driving unit and drilling equipment were specially designed for one another and formed an integral mechanical unit. The Tribunal relied on expert evidence, the manufacturer's certificate and HSN explanatory notes, and noted that Customs had earlier accepted the classification under Heading 84.30. The Revenue failed to produce the original examination report or a technical rebuttal, so it did not discharge the burden of proving the rival classification. The consequential differential duty demand was therefore not sustainable.

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Issues: Whether the imported truck-mounted drilling rig was classifiable under Heading 84.30 of the Customs Tariff as a self-propelled boring or sinking machine, or under Heading 87.05 as a special purpose motor vehicle, and whether the consequential differential duty demand was sustainable.

Analysis: The goods had earlier been examined by Customs and accepted under Heading 84.30, while the Department later sought reclassification under Heading 87.05. The appellant produced technical evidence from an expert and a manufacturer's certificate showing that the chassis, driving unit, and drilling rig were specially designed for each other, formed an integrated mechanical unit, and could not be separated for any other use. The record also showed that the Department did not produce the original examination report or rebut the expert material by technical inspection. Applying the HSN explanatory notes, the Tribunal held that a machine is classifiable under Heading 84.30 where the chassis and working machine are specially designed for each other and form an integral mechanical unit, and that the Revenue must discharge the burden of proving a rival classification.

Conclusion: The imported goods were held classifiable under Heading 84.30 and not under Heading 87.05, and the differential duty demand was not sustainable.

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