Section Note 2(a) prevails for machine parts classification, and specially designed components remained within the tariff treatment.

Specific classification under Section Note 2(a) of Section XVI governed the disputed machine parts, and the note was held to apply on the facts. The items were treated as distinct components within the tariff scheme, and their alleged special design for use in a particular machine did not take them outside the prescribed treatment where the note squarely covered them. The earlier Tribunal ruling relied on by the appellant was found inapplicable because it concerned different goods. The lower authorities' classification was upheld and the appeal was dismissed.

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Issues: Whether the disputed machine parts were classifiable in terms of Section Note 2(a) of Section XVI of the Central Excise Tariff Act, 1985, and whether they could be excluded from that treatment on the ground that they were specially designed for use in a particular machine.

Analysis: Section Note 2(a) of Section XVI was held to be specific and applicable on the facts. The items were treated as distinct components falling within the classification structure governed by the note, and the earlier Tribunal decision relied upon by the appellant was held inapplicable because it concerned different goods. The binding effect of the section note was emphasised for determining classification of parts.

Conclusion: The classification adopted by the lower authorities was upheld and the appellant's challenge failed.

Final Conclusion: The appeal was dismissed and the impugned classification was confirmed.

Ratio Decidendi: For classification under Section XVI, a specific section note governing parts prevails, and specially designed machine parts do not escape the prescribed tariff treatment where the note squarely applies to them.

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