Classification of vehicle seat parts turned on specific tariff headings and chapter notes, with rubber seat-shaped goods treated as seat parts.

Vulcanised rubber goods cut to the shape of vehicle seats were treated as parts of seats rather than as general rubber products, because Tariff Heading 94.01 specifically covers seats and parts thereof while Tariff Heading 40.08 is residual in nature. The chapter notes were read together so that articles falling within Chapter 94 were excluded from Chapter 40, and the HSN Explanatory Notes supported that classification. For two-wheeler seats, however, the exclusion in Chapter Note 1(h) kept them outside Chapter 94 and placed them under Tariff Heading 87.14. The note also records that the Tribunal was bound by earlier coordinate bench rulings on the same issue.

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Issues: Whether vulcanised rubber goods cut to the shape of seats of motor vehicles and two wheelers were classifiable under Tariff Heading 94.01 or Tariff Heading 40.08, and whether the exclusionary chapter notes displaced classification under Heading 94.01.

Analysis: The goods were not mere cushions in the abstract but articles cut to the shape of seats and used only in seats of vehicles. Tariff Heading 94.01 specifically covers seats and parts thereof, while Tariff Heading 40.08 is a general entry for vulcanised rubber products. Chapter Note 1(a) to Chapter 94 excludes cushions of Chapter 40, but Chapter Note 2(e) to Chapter 40 excludes articles falling under Chapter 94. On the facts found, the goods were parts of seats and therefore fell within the more specific heading. The HSN Explanatory Notes supported this construction. As regards two wheeler seats, Chapter Note 1(h) excluded articles of heading 87.14, so seats of two wheelers were not brought under Chapter 94 and instead fell under Tariff Heading 87.14. Chapter Note 2 to Chapter 94 did not assist the assessee because seats of vehicles are placed on the floor of the vehicle and are covered by the expression used in that note. Chapter Note 9 to Chapter 40 also did not alter the result. The Tribunal was additionally bound to follow its earlier coordinate bench decisions on the same classification issue.

Conclusion: The goods were classifiable under Tariff Heading 94.01 and not under Tariff Heading 40.08; the contrary view of the Tribunal was unsustainable, and the appeal succeeded.

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