Tariff classification of industrial cattle feed plant machinery falls under the residuary heading, not the animal feeding stuffs heading.

Imported cattle feed plant machinery was held classifiable under Heading 8479, not Heading 8436, because Heading 8436 is confined to machinery associated with agricultural or similar non-industrial activities and cannot be stretched to cover a complete industrial cattle feed manufacturing plant. The tariff heading must be satisfied first on its own terms, and HSN explanatory notes operate only as an interpretative aid where consistent with the heading. As the goods were multiple machines functioning together for industrial production and did not fit Heading 8436, they were correctly classified under the residuary heading in favour of Revenue.

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Issues: Whether the imported cattle feed plant machinery was classifiable under Heading 8436 as machinery for preparing animal feeding stuffs, or under Heading 8479 as machines and mechanical appliances having individual functions not specified elsewhere.

Analysis: The imported goods comprised a complete 500 TPD cattle feed manufacturing plant consisting of multiple machines working together for industrial production. Heading 8436 was held to cover machinery of the kind associated with agricultural, horticultural, forestry, poultry-keeping or bee-keeping activities, and not machinery clearly designed for industrial use. The sub-heading for machinery for preparing animal feeding stuffs could not be enlarged to include a complete industrial cattle feed plant. Since the goods did not fit within Heading 8436, they could not be classified under its sub-heading. Heading 8479, being a residuary heading for machines having individual functions not specified elsewhere in Chapter 84, appropriately covered the imported machinery. The HSN explanatory notes were treated as a valid guide consistent with the tariff structure, but not as overriding the tariff headings.

Conclusion: The goods were not classifiable under Heading 8436 and were correctly classified under Heading 8479; the classification in favour of Revenue was upheld.

Ratio Decidendi: Classification must first satisfy the scope of the tariff heading itself, and HSN explanatory notes may be used only as an interpretative aid where consistent with the heading; machinery designed for industrial use cannot be forced into a heading meant for agricultural or similar non-industrial machinery.

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