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Issues: Whether the imported semi-finished jeep transmission synchroniser blocking rings were classifiable under Heading 84.63 of the Customs Tariff Act, 1975 or under Heading 87.04/06(1) as parts of a motor vehicle.
Analysis: Heading 84.63 covers transmission shafts, gears, gear boxes and related mechanical parts, but the classification of motor vehicle parts is governed by Section XVII of the Import Tariff. Section Note 2(e) of Section XVII excludes from that Section machines and mechanical appliances falling under Heading 84.63, while Section Note 1(k) of Section XVI excludes vehicles of Section XVII. Since jeep falls within Heading 87.02 and the goods related to the gear box of a jeep, the appropriate classification was under Heading 87.04/06(1) as parts of a motor vehicle not elsewhere specified. The appellants did not establish, on the materials before the Tribunal, that the semi-finished articles lacked the essential character of finished gear-box parts, and the interpretative rules did not assist them on the facts.
Conclusion: The goods were correctly assessed under Heading 87.04/06(1) and not under Heading 84.63; the assessee's classification claim failed.
Ratio Decidendi: For tariff classification, the specific section notes governing the relevant chapter and section prevail, and parts of a motor vehicle are to be classified under the motor vehicle heading rather than a more general mechanical heading when the goods relate to a vehicle component covered by Section XVII.