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Issues: (i) Whether U-bolt and Centre Bolt are classifiable under Heading 7318 of the First Schedule to the Customs Tariff Act, 1975 and the applicable rate of tax; (ii) Whether Spring Pin is classifiable under Heading 7320 of the First Schedule to the Customs Tariff Act, 1975 and the applicable rate of tax; (iii) Whether Bush is classifiable under Heading 8708 of the First Schedule to the Customs Tariff Act, 1975 or under Heading 8483 of the First Schedule to the Customs Tariff Act, 1975 and the applicable rate of tax.
Issue (i): Whether U-bolt and Centre Bolt are classifiable under Heading 7318 of the First Schedule to the Customs Tariff Act, 1975 and the applicable rate of tax.
Analysis: Note 2(b) to Section XVII excludes parts of general use from the expression "parts" and "parts and accessories", while Note 2(a) of Section XV treats articles of Heading 7318 as parts of general use. The HSN Explanatory Notes to Heading 7318 expressly include U-bolts, and the Centre Bolt answers the description of a bolt because it is threaded and designed to engage with a nut. Such goods are therefore classifiable under Heading 7318 and not as motor vehicle parts under Section XVII.
Conclusion: U-bolt and Centre Bolt are classifiable under Heading 7318 15 00 and taxable at 18%.
Issue (ii): Whether Spring Pin is classifiable under Heading 7320 of the First Schedule to the Customs Tariff Act, 1975 and the applicable rate of tax.
Analysis: The tariff specifically provides for Spring Pins under tariff item 7320 90 20. Heading 7320 covers springs and leaves for springs, of iron or steel, and the product is a steel article of that nature. The General Rules for the Interpretation of the tariff therefore support classification under the specific entry rather than any competing heading.
Conclusion: Spring Pin is classifiable under Heading 7320 90 20 and taxable at 18%.
Issue (iii): Whether Bush is classifiable under Heading 8708 of the First Schedule to the Customs Tariff Act, 1975 or under Heading 8483 of the First Schedule to the Customs Tariff Act, 1975 and the applicable rate of tax.
Analysis: Heading 8708 applies only to parts and accessories of motor vehicles that are identifiable as suitable solely or principally for such vehicles and are not excluded by the notes to Section XVII. Plain shaft bearings are specifically referred to in Heading 8483, and the explanatory notes to Heading 8708 also exclude the relevant bearing-related items from Section XVII coverage. On the facts, the Bush falls within the bearing-related entry of Heading 8483 rather than motor vehicle parts.
Conclusion: Bush is classifiable under Heading 8708 99 00 and taxable at 28%.
Final Conclusion: The ruling settles the tariff classification of the three products by applying the section notes, chapter notes and explanatory notes to place the fasteners in Heading 7318, the Spring Pin in Heading 7320, and the Bush in the motor-vehicle related tariff structure identified by the Authority, with the stated tax rates.
Ratio Decidendi: For tariff classification, the specific heading, section and chapter notes, and the HSN explanatory notes govern over a broader functional description, and articles expressly treated as parts of general use or specifically named in a heading are to be classified in that heading rather than as motor-vehicle parts.