Mounted loader classification: equipment fabricated on a tractor falls under Heading 87.05, not material handling machinery.

A loader fabricated on and mounted to a tractor was classified as a special purpose motor vehicle under Heading 87.05, not as material handling equipment under Heading 84.29. The classification turned on the fact that the loader was not an independent self-propelled machine with its own propelling base, operating controls, working tools and actuating equipment forming an integral mechanical unit. Note 3 to Chapter 87 and the HSN Explanatory Notes supported treatment of machinery mounted on tractors within Chapter 87, while the Chapter 84 discussion did not justify classification under Heading 84.29.

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Issues: Whether a loader fabricated on a tractor is classifiable under Heading 87.05 as a special purpose motor vehicle or under Heading 84.29 as material handling equipment.

Analysis: The fabricated loader was mounted on a tractor and was not shown to be an independent self-propelled machine with a specially designed propelling base, operating controls, working tools and actuating equipment forming an integral mechanical unit. Note 3 to Chapter 87 treated fabrication or mounting on a chassis as manufacture of a motor vehicle, and the HSN Explanatory Notes indicated that machines mounted on tractors fall within Chapter 87. The discussion under Heading 84.30, applied mutatis mutandis to Heading 84.29, did not support classification of the impugned goods under Chapter 84, while the notes under Heading 87.05 covered such special purpose vehicles.

Conclusion: The loader fabricated on the tractor was classifiable under Heading 87.05 and not under Heading 84.29, in favour of the assessee.

Ratio Decidendi: A machine mounted on a tractor, where the tractor remains the base and the equipment is not an independently designed self-propelled unit, is classifiable as a special purpose motor vehicle under Heading 87.05 rather than as material handling machinery under Chapter 84.

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