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Issues: Whether rotors and stators manufactured for captive use in monobloc pumps were classifiable under Tariff Item 30D as parts of electric motors, or under Tariff Item 68 as residuary goods.
Analysis: The rotors and stators were found to be specially designed for monobloc pumps, not interchangeable, and incapable of use in electric motors. The trade notice could not support classification of parts of a non-existent electric motor where no electric motor came into existence as an identifiable and separable article. Since the manufacturer was assessed to duty on the monobloc pumps and the tariff, as it then stood, did not separately provide for parts of monobloc pumps, the goods fell within the residuary entry.
Conclusion: The rotors and stators were not classifiable under Tariff Item 30D and were correctly classifiable under Tariff Item 68.
Final Conclusion: The Revenue's challenge to the Tribunal's classification finding failed, and the appeals stood dismissed.
Ratio Decidendi: Where components are specially manufactured for a specific end-product and cannot be used as parts of the article named in the tariff entry, they cannot be classified under that entry merely because of a trade notice; in the absence of a specific tariff item, residuary classification applies.