Tariff classification of hydraulic pump favours specific heading over machine part classification

A hydraulic pump supplied with a hydraulic press was treated as classifiable under Heading 84.13 as a pump for liquids, because it retained an independent identity and was specifically covered by its own tariff heading. Separate invoicing, ordering, description in technical literature and separate charging supported classification on that basis. Section Note 2(a) of Section XVI required goods falling within a specific heading to be classified there, while Section Note 4 did not apply because the pump was not merely a component giving the press a single defined function. The HSN Explanatory Notes also supported separate classification even where the pump was specially designed to work with the machine.

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Issues: Whether the hydraulic pump manufactured and supplied with the hydraulic press was classifiable under Heading 84.13 as a pump for liquids, or under Heading 84.53 as part of the hydraulic press.

Analysis: The tariff entries specifically covered pumps for liquids under Heading 84.13, while Heading 84.53 did not include parts or accessories of the machinery described therein. The pump and press were separately invoiced, separately ordered, separately described in the technical literature, and separately charged, indicating that the pump had an independent identity. Section Note 2(a) of Section XVI required goods included in a chapter heading to be classified in their respective headings, and the material did not support treating the pump as a component of the press. Section Note 4 of Section XVI was inapplicable because the pump was not an individual component contributing to a single defined function of the press. The HSN Explanatory Notes also supported classification of pumps in their own heading even when specially designed to work with a particular machine.

Conclusion: The hydraulic pump was rightly classifiable under Heading 84.13 and not under Heading 84.53. The classification adopted by the Revenue was unsustainable.

Final Conclusion: The impugned orders were set aside and the appeal succeeded with consequential relief.

Ratio Decidendi: A goods article specifically covered by its own tariff heading must be classified in that heading and cannot be treated as a part of another machine merely because it functions with that machine, unless the statutory scheme clearly requires composite classification.

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