Railway locomotive parts classification under Heading 8607 attracts the notified GST rate for that tariff entry.

Filter elements and air filter assemblies manufactured to railway-approved specifications and principally used with locomotives fall within Heading 8607 as parts of railway locomotives. Classification was determined under the Customs Tariff Act, with Section XVII Note 3 requiring parts and accessories to be suitable solely or principally for use with the relevant articles. Once classified under Heading 8607, the applicable GST rate followed the notified entry for that heading, attracting 5% GST under the relevant rate notification.

---

---

Issues: (i) Whether the Filter Elements and Air Filter Assembly manufactured as per railway specifications were classifiable under Tariff Heading 8607 as parts of railway locomotives; (ii) whether the goods were liable to GST at the rate prescribed for Heading 8607.

Issue (i): Whether the Filter Elements and Air Filter Assembly manufactured as per railway specifications were classifiable under Tariff Heading 8607 as parts of railway locomotives

Analysis: The classification was examined under Notification No. 1/2017-Central Tax (Rate) dated 28-6-2017, read with the Customs Tariff Act, 1975. Heading 8607 covers parts of railway or tramway locomotives or rolling-stock. Note 3 of Section XVII of the Customs Tariff Act, 1975 requires that parts or accessories in Chapters 86 to 88 must be suitable solely or principally for use with those articles, and classification follows the principal use where more than one heading may apply. The goods were found to be manufactured to railway-approved specifications and principally used with locomotives.

Conclusion: Yes. The goods were correctly classifiable under Tariff Heading 8607.

Issue (ii): Whether the goods were liable to GST at the rate prescribed for Heading 8607

Analysis: Once classified under Heading 8607, the applicable rate followed the entry prescribed for that heading in Notification No. 1/2017-Central Tax (Rate) dated 28-6-2017 issued under the Central Goods and Services Tax Act, 2017.

Conclusion: Yes. The applicable GST rate for Heading 8607 was 5%.

Final Conclusion: The ruling accepted the applicant's classification of the goods under Heading 8607 and applied the corresponding GST rate for that heading.

Ratio Decidendi: Goods manufactured for and principally used with railway locomotives are classifiable as parts of railway locomotives under Heading 8607, and the GST rate applicable to that heading follows the notified tariff entry.

---