Tariff classification of hauling vehicles follows the express heading definition, not registration labels, for tractors under Heading 87.01.

Tariff classification of a three-wheeled tractor-like hauling unit turned on Chapter Note 2 to Chapter 87, which defines tractors as vehicles constructed essentially for hauling or pushing another vehicle, appliance or load. Because the vehicle had no payload capacity of its own and was coupled to a semi-trailer, the explanatory notes to Heading 87.01 supported treatment as a tractor, and registration as a light motor goods carriage was not determinative. The article notes that, where the tariff contains an express definition, classification must follow that definition and the heading notes rather than common parlance. The vehicle was therefore classifiable under Heading 87.01 as a tractor, not as a light motor vehicle.

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Issues: Whether the three-wheeled tractor-like vehicle used for hauling a semi-trailer was classifiable as a tractor under Heading 87.01 or as a light motor vehicle, and consequently eligible for the claimed treatment under the tariff and exemption notification.

Analysis: Chapter Note 2 of Chapter 87 defined tractors as vehicles constructed essentially for hauling or pushing another vehicle, appliance or load, whether or not they contained subsidiary provision for transport connected with the main use. The vehicle in question consisted of a hauling unit coupled with a semi-trailer and had no payload capacity of its own. The earlier view under the erstwhile tariff was not conclusive because the new tariff contained an express definition, and the explanatory notes to Heading 87.01 specifically covered tractors coupled to semi-trailers and articulated motor vehicles. The opinions obtained from technical bodies also supported the view that the hauling unit was a tractor and that RTO registration as a light motor goods carriage was not determinative of tariff classification.

Conclusion: The vehicle was classifiable as a tractor under Heading 87.01 and not as a light motor vehicle; the assessee was therefore entitled to succeed.

Ratio Decidendi: Where the tariff expressly defines a product, classification must follow that statutory definition and the relevant heading notes, and not common parlance, if the goods satisfy the defined characteristics.

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