Specific tariff heading prevails over machine-part classification, with the step and repeat machine and lamp unit reassessed accordingly.

The step and repeat machine was classified under Heading 84.40 by following an earlier Tribunal view, and the mercury vapour lamp unit without bulb was classified under Heading 85.18/27(1) because a specific tariff heading was available for the item. Both items were directed to be re-assessed accordingly, with consequential relief where due. The note confirms that a specific heading prevails over treatment as a mere part of another machine, and that an accepted prior classification may be followed where there is no effective dispute on duty impact.

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Issues: (i) Whether the step and repeat machine was classifiable under Heading 84.40; (ii) Whether the mercury vapour lamp unit without bulb was classifiable as a part of the machine under Heading 84.40 or under Heading 85.18/27(1) as a specific item.

Issue (i): Whether the step and repeat machine was classifiable under Heading 84.40.

Analysis: The accepted classification of the same machine in an earlier Tribunal decision was followed. Since both sides accepted Heading 84.40 and there was no difference in the rate of duty, the question of re-opening the classification was not pursued.

Conclusion: The step and repeat machine was held classifiable under Heading 84.40 and was directed to be re-assessed accordingly, with consequential relief to the assessee.

Issue (ii): Whether the mercury vapour lamp unit without bulb was classifiable as a part of the machine under Heading 84.40 or under Heading 85.18/27(1) as a specific item.

Analysis: A specific heading was available for the lamp unit itself. On that basis, it was not to be treated as merely a part of the machine, and the original claim for classification under Heading 85.18/27(1) with the relevant exemption notification was accepted.

Conclusion: The lamp unit was held classifiable under Heading 85.18/27(1) and was directed to be re-assessed accordingly, with consequential relief if due.

Final Conclusion: The appeal succeeded in part, with the machine and lamp unit directed to be classified under different headings and re-assessed accordingly.

Ratio Decidendi: Where a specific tariff heading is available for an item, it should be classified under that heading rather than as a mere part of another machine; an accepted earlier classification may also be followed when there is no effective dispute on duty impact.

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