Rice par-boiling machinery classifies under Heading 8419 because its temperature-treatment function prevails over rice-milling use.

Rice par-boiling machinery and dryers are classifiable under Heading 8419 because they perform steaming, soaking, drying and moisture reduction, which are function-specific processes for treatment of materials by change of temperature. Classification must be determined from the goods as manufactured and cleared, not by their later use in a composite rice-milling line. Heading 8437, being an industry-specific entry for rice-milling machinery, does not prevail over the more specific Heading 8419 on these facts. The classification therefore falls under Heading 8419 and not Heading 8437.

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Issues: Whether rice par-boiling machinery and dryers are classifiable under Heading 8419 or under Heading 8437 of the Central Excise Tariff Act.

Analysis: The machinery performs steaming, soaking, drying and moisture reduction of paddy, which are function-specific processes squarely covered by Heading 8419. Although the machinery may be used in conjunction with a rice mill, classification has to be determined on the basis of the goods as manufactured and cleared from the factory, not on their subsequent use in a composite rice-milling line. The reliance on Notes 3 and 4 to Section XVI and Note 2 to Chapter 84 was rejected because Heading 8419 is a specific heading for machinery used for treatment of materials by change of temperature, whereas Heading 8437 is an industry-specific entry for rice-milling machinery. The process is also not a mere grain dampening activity, since it includes soaking, steaming and drying.

Conclusion: Rice par-boiling machinery and dryers are classifiable under Heading 8419 and not under Heading 8437; the classification favours the Revenue.

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