Specific tariff heading for moulds prevails over general parts heading when machinery moulds are independently classifiable.

Ceramic machinery moulds were held classifiable under the specific tariff heading for moulds rather than as parts of machinery under the general parts-and-accessories heading. The goods were expressly described as moulds, and Section Note 2 of Section XVI required classification in the heading applicable to Chapter 84 goods. Because the machinery remained complete without the moulds and the moulds functioned independently, they were not treated as parts or accessories of the machine. The specific-heading rule prevailed over the general residual heading, resulting in classification under the moulds entry.

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Issues: Whether the moulds used in machinery for producing ceramic products were classifiable under Heading 84.66 as parts of machinery or under the specific heading covering moulds.

Analysis: The goods were admitted to be moulds and were specifically described in Heading 84.40 of the Tariff, which covers moulds of the relevant kind. Under Section Note 2 of Section XVI, goods included in any heading of Chapter 84 or 85 must be classified in their respective headings. The machinery remained complete even without the moulds, and the moulds functioned independently; they were therefore not parts or accessories of the machine. The principle that a specific entry overrides a general entry supported classification under the heading specifically covering moulds rather than the residual parts heading.

Conclusion: The moulds were not classifiable under Heading 84.66 and were correctly classified under the specific heading for moulds. The finding was against the assessee and in favour of Revenue.

Ratio Decidendi: Where goods are specifically covered by a tariff heading, they must be classified under that specific heading and excluded from a more general parts-and-accessories heading.

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