Motor vehicle body classification on supplied chassis falls under Heading 87.07, despite a contrary Board circular.

Bodies fabricated by independent body builders on customer-supplied motor vehicle chassis were held classifiable under Heading 87.07, not Heading 87.02, under the Central Excise Tariff. The Tribunal applied the settled judicial position on the tariff entry for such fabricated bodies and rejected the contrary Board circular, holding that administrative guidance cannot displace later binding judicial interpretation once classification has been settled. The result was that the classification dispute was resolved in favour of Heading 87.07.

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Issues: Whether body built on motor vehicle chassis is classifiable under Heading 87.02 or Heading 87.07 of the Central Excise Tariff Act.

Analysis: The dispute turned on the correct tariff entry for bodies fabricated by independent body builders on chassis supplied by customers. The Tribunal followed the settled position that such bodies fall under Heading 87.07. It also held that a Board circular contrary to the later binding judicial interpretation could not alter the classification once the issue had been judicially ined.

Conclusion: The body built on chassis supplied by the customer was classifiable under Heading 87.07 and not under Heading 87.02, and the appeals failed.

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