Specific tariff classification for tailor-made machine parts prevails over general pump-part classification under Chapter 84.

Parts such as pump shafts, when themselves covered by a specific heading in Chapter 84, are classified under that heading rather than as general parts of power driven pumps. Note 2(a) to Section XVI of the Central Excise Tariff Act, 1985 requires classification in the specific heading even where the parts are machined, tailor-made, or used only with a particular machine. The commentary also notes that earlier authorities support this approach and that the claim for exemption on captively consumed goods was not accepted on the facts discussed.

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Issues: Whether pump shafts and other parts captively used in the manufacture of power driven pumps were classifiable under the specific tariff headings applicable to those parts or as parts of power driven pumps, and whether the exemption claimed on captively consumed goods was available.

Analysis: The goods in dispute were found to be parts which, by their nature, fell under specific headings within Chapter 84 rather than remaining classifiable as general parts of power driven pumps. Applying Note 2(a) to Section XVI of the Central Excise Tariff Act, 1985, parts which are themselves goods included in a separate heading must be classified in that heading even if they are machined or tailor-made for use with a particular machine. The earlier decisions relied upon supported the same principle that modified or specialized machine parts retain classification under their respective headings. The appellant's claim that the parts were not intended for separate classification and that the department had not discharged the burden of proof was not accepted.

Conclusion: The classification adopted by the revenue was correct and the demand was upheld.

Ratio Decidendi: Where a machine part is itself covered by a specific heading in Chapter 84, it must be classified under that heading notwithstanding that it is tailor-made or used solely with a particular machine, by virtue of Note 2(a) to Section XVI of the Central Excise Tariff Act, 1985.

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