Tariff classification turns on the goods at clearance, not later vehicle use, for cold formed steel panels.

Cold formed steel panels cut to size were held to answer the tariff description of angles, shapes and sections with a uniform solid cross-section under sub-heading 7216.20. Their potential use in light commercial vehicles did not by itself make them motor vehicle parts under sub-heading 8708.00, because classification depends on the condition of the goods at clearance and not on later processing by the buyer. The specific tariff heading prevailed over the more general use-based heading, and subsequent strengthening, welding, fitting of hinges, and similar work by customers could not alter the original classification.

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Issues: Whether the goods manufactured by the appellant, being cold formed panels cut to size for use in light commercial vehicles, were classifiable under sub-heading 7216.20 as angles, shapes and sections not further worked than cold formed or cold finished, or under sub-heading 8708.00 as parts and accessories of motor vehicles.

Analysis: The goods were produced from steel sheets and strips by cold forming and cutting to size, but they were not subjected to further processing before clearance. The Chapter Note defining angles, shapes and sections covered products having a uniform solid cross-section, and the goods answered that description. HSN guidance showed that such lighter products may be used in making automobiles, but user in vehicle manufacture does not by itself convert them into motor vehicle parts unless further working is carried out. The panels became vehicle body parts only after subsequent strengthening, welding, fitting of hinges, and related processes by the customers. The principle of tariff interpretation required the more specific description to prevail over the more general one, and ultimate use after clearance could not control classification. The earlier decision treating differently processed tailor-made panels as motor vehicle parts was confined to its facts.

Conclusion: The goods were classifiable under sub-heading 7216.20 and not under sub-heading 8708.00, and the classification proposed by the department was rejected.

Ratio Decidendi: Where goods answer a specific tariff description based on their condition at the time of clearance, subsequent end-use or further processing by the buyer does not alter their classification, and the specific heading prevails over a more general use-based heading.

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