Specific tariff heading prevails for railway coach seats, keeping them under Heading 9401 and attracting GST at 18%.

Railway coach seats and their parts remain classifiable under Heading 9401 when the tariff specifically describes them as seats, even if they are used exclusively in railway coaches. Classification under GST must follow the tariff schedule, section notes, chapter notes and interpretative rules; under Rule 3(a), the more specific heading prevails over the broader heading for railway rolling-stock parts in Heading 8607. Chapter Note 2 to Chapter 86 does not exclude such seats from Heading 9401, and the cited departmental circular supports that view. The product is therefore classified under Heading 9401 and attracts GST at 18%.

---

---

Issues: Whether railway seats and parts thereof used exclusively in railway coaches are classifiable under Heading 9401 or Heading 8607, and the consequent applicable GST rate.

Analysis: Classification under GST is to be determined in accordance with the tariff schedule, section notes, chapter notes and interpretative rules, rather than by trade parlance where the tariff gives a clear answer. Heading 9401 specifically covers seats and parts thereof, whereas Heading 8607 deals with parts of railway or tramway locomotives or rolling stock in general terms. Rule 3(a) requires preference to the heading providing the most specific description. Chapter Note 2 to Chapter 86 does not cover seats, and the cited departmental circular also recognises railway coach seats as classifiable under Heading 9401. On the tariff structure, seats meant for railway coaches are therefore not taken out of Heading 9401 merely because they are fitted in rail coaches.

Conclusion: The product is classifiable under Heading 9401 and attracts GST at 18%.

Ratio Decidendi: Where a product is specifically described as seats and parts thereof, that specific heading prevails over a broader heading for railway rolling-stock parts, and railway coach seats remain classifiable under the seats heading.

---