Vehicle classification under the tariff depends on design features, load capacity, and whether goods or passenger transport is principal.

Classification of Mahindra Bolero Camper variants turns on whether the vehicle is principally designed for the transport of persons under Heading 8703 or for the transport of goods under Heading 8704. The note explains that classification depends on design features, Chapter Note guidance on station wagons, and HSN guidance, with decisive indicators including gross vehicle weight distribution, load-carrying capacity, registration as a goods vehicle, and structural features. On the recorded materials, the goods-carrying capacity exceeded passenger-carrying capacity, and the vehicle did not exhibit the characteristics of a station wagon or a passenger-principally designed vehicle.

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Issues: Whether the impugned Mahindra Bolero Camper variants were classifiable under Heading 8703 of the Central Excise Tariff Act, 1985 as motor vehicles principally designed for the transport of persons, including station wagons, or under Heading 8704 as motor vehicles for the transport of goods.

Analysis: The tariff entry for Heading 8703 requires that the vehicle be principally designed for the transport of persons, while Heading 8704 covers motor vehicles for the transport of goods. The Court compared the competing tariff entries, the Chapter Note defining station wagons, and the HSN guidance indicating that classification depends on the design features showing whether the vehicle is primarily meant for passengers or goods. Applying the earlier precedent approved by the Supreme Court, the Court treated the distribution of gross vehicle weight, the load-carrying capacity, the registration as a goods vehicle, and the structural features of the vehicle as decisive indicators. On the materials placed on record, the goods-carrying capacity was greater than the passenger-carrying capacity, and the vehicle did not satisfy the characteristics of a station wagon or a vehicle principally designed for passengers.

Conclusion: The impugned vehicles were not classifiable under Heading 8703 and were correctly classifiable under Heading 8704; the assessee succeeded.

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