Tariff classification of motor vehicle parts follows the more specific heading where explanatory notes exclude competing entries.

Tariff classification of Starter Ring Gear, Universal joint Cross and Starter Ring Gear Flywheel Assembly was determined by comparing the competing headings and applying the interpretative rules under the GST rate notification. Heading 8708 was treated as covering parts and accessories of motor vehicles, while heading 8483 covered transmission components such as flywheels, gears and universal joints; the Explanatory Notes to heading 87.08 excluded internal engine parts falling under heading 84.83. On that basis, Starter Ring Gear and Universal joint Cross were classified under heading 8708 and taxed at 28%, while Starter Ring Gear Flywheel Assembly was classified under heading 8483 and taxed at 18%.

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Issues: Whether Starter Ring Gear, Universal joint Cross (U.J. Cross), and Starter Ring Gear Flywheel Assembly are classifiable under heading 8708 or 8483, and the GST rate applicable thereto.

Analysis: The classification was determined by applying the tariff headings and the interpretative rules made applicable through the rate notification. Heading 8708 covers parts and accessories of motor vehicles, while heading 8483 covers transmission components including flywheels, gears, and universal joints. The Explanatory Notes to heading 87.08 exclude internal engine parts such as crank shafts, cam shafts, and flywheels of heading 84.83. On that basis, the goods required item-wise classification according to their tariff description and use.

Conclusion: Starter Ring Gear and Universal joint Cross (U.J. Cross) were held classifiable under heading 8708 and taxable at 28%. Starter Ring Gear Flywheel Assembly was held classifiable under heading 8483 and taxable at 18%.

Final Conclusion: The ruling granted partial relief by accepting different classifications for the goods in question and applying the corresponding GST rates accordingly.

Ratio Decidendi: Where a product answers the description of a more specific tariff heading and the applicable explanatory notes exclude it from another heading, classification must follow the heading that more specifically covers the goods.

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