Tariff classification of automobile hinges follows Heading 8302.00 as base metal fittings, not motor vehicle parts.

Hinges and similar components manufactured for motor vehicles were held to fall under Heading 8302.00 as base metal fittings, not under Heading 8708.00 as motor vehicle parts and accessories. The classification turned on the scope of Heading 8302.00 and the HSN Explanatory Notes, which treat base metal mountings and fittings for doors and similar uses as covered by that heading even when designed for a specific application, including automobile door hinges. The text also notes the general principle that tariff classification should follow HSN Explanatory Notes unless the Central Excise Tariff shows a contrary intention.

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Issues: Whether hinges and components thereof manufactured for motor vehicles were classifiable under Heading 8708.00 of the Central Excise Tariff as parts and accessories of motor vehicles, or under Heading 8302.00 of the Central Excise Tariff as fittings of base metal.

Analysis: Heading 8708.00 covers parts and accessories of motor vehicles, while Heading 8302.00 covers base metal mountings, fittings and similar articles suitable for doors and similar uses. The HSN Explanatory Notes to Heading 8302.00 specifically state that goods of that general class remain covered by that heading even if designed for particular use, including door hinges for automobiles. The Supreme Court has also held that tariff classification should, as far as possible, follow the HSN Explanatory Notes unless the Central Excise Tariff indicates a different intention.

Conclusion: The goods were correctly classified under Heading 8302.00 of the Central Excise Tariff. The challenge to the classification failed.

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