Tariff classification of imported crank shafts upheld under the specific heading, with the alternative entry rejected.

Imported crank shafts with spares were classified as transmission shafts falling within Heading 84.63 of the Customs Tariff Act, 1975, because the goods answered to the specific tariff description and were supported by Section Note 2(a) to Section XVI. The alternative claim for classification under Heading 84.11(1) was rejected, as a specific heading prevails over a more general or competing description when the goods squarely fit the former.

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Issues: Whether the imported crank shaft with spares was classifiable under Heading 84.63 of the Customs Tariff Act, 1975 or under Heading 84.11(1) of the Customs Tariff Act, 1975.

Analysis: The imported goods were found to consist of crank shafts, which are transmission shafts. On that factual basis, the goods fell within the specific coverage of Heading 84.63. Section Note 2(a) to Section XVI also supported the classification adopted by the customs authorities.

Conclusion: The classification under Heading 84.63 was upheld and the claim for reclassification under Heading 84.11(1) was rejected.

Ratio Decidendi: Where imported goods answer to a specific tariff description and are supported by the relevant section note, they are to be classified under that specific heading rather than under a claimed alternative heading.

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