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Issues: Whether the roof mounted air-conditioning unit manufactured for railway coaches was classifiable under Heading 8415 as an air-conditioning machine or under Heading 8607 as parts of railway rolling stock.
Analysis: Heading 8415 specifically covers air-conditioning machines, while Heading 8607 is a general provision for parts of railway locomotives or rolling stock. Under the tariff rules of classification, a specific heading prevails over a general heading. Section XVII Note 2(e) excludes machines and apparatus of headings 8401 to 8479 from the scope of parts and accessories for Section XVII, so a good classifiable as an air-conditioning machine cannot be treated as a part of railway rolling stock merely because it is supplied for use in railways. The explanatory notes further show that classification depends on the function of the goods and not on the industry or vehicle in which they are used. The conditions for Heading 8607 were not satisfied because the goods were excluded by the section notes.
Conclusion: The roof mounted air-conditioning unit is classifiable under Heading 8415 and not under Heading 8607; the appeal fails.