Truck mounted cranes on complete goods trucks fall under special purpose motor vehicles, not crane classification.

Truck mounted cranes manufactured by fitting cranes on complete trucks or lorries designed for goods transport are classifiable as special purpose motor vehicles under heading 8705, not as cranes under heading 8426. Heading 8426 covers cranes and works trucks fitted with a crane, but where the crane is mounted on a readymade truck chassis or lorry, the finished article answers the description of a motor vehicle under heading 8704/8705. The ruling relies on the HSN Explanatory Notes as a dependable aid to tariff interpretation and adopts the view that the composite product is not a works truck crane but a special purpose vehicle.

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Issues: Whether truck mounted cranes manufactured by mounting cranes on readymade trucks or lorries are classifiable under heading 8426 or under heading 8705.

Analysis: Heading 8426 covers cranes, mobile lifting frames, straddle carriers and works trucks fitted with a crane. The product in question was manufactured not on a works truck but on readymade trucks and lorries meant for transport of goods under heading 8704. Once a crane is mounted on such an automobile chassis or lorry, the resultant goods answer the description of special purpose motor vehicles under heading 8705. The Explanatory Notes to heading 87.05 support this classification, and HSN Explanatory Notes are a dependable guide for tariff interpretation.

Conclusion: The truck mounted cranes are not classifiable under heading 8426; they are classifiable under heading 8705, in favour of Revenue.

Ratio Decidendi: Where a crane is mounted on a complete truck or lorry designed for transport of goods, the resultant article is a special purpose motor vehicle under heading 8705 and not a crane under heading 8426.

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