Specific tariff heading prevails for chaff cutter blades, confirming classification under Heading 8208 and GST liability.

Blades cleared as spare parts for chaff cutter machines were held classifiable under heading 8208 40 00 as knives and cutting blades for agricultural, horticultural or forestry machines. The tariff description, Section and Chapter Notes, and HSN Explanatory Notes controlled the classification, and the specific coverage of blades for straw cutters in Heading 82.08 prevailed. Chapter XVI could not apply because it excludes articles covered by Chapter 82, and the exclusionary notes to Heading 84.36 also supported that result. The goods were therefore liable to GST at 18% under heading 8208 40 00, not under heading 8436 10 00.

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Issues: Whether blades cleared as spare parts for chaff cutter machines are classifiable under heading 8208 40 00 as knives and cutting blades for agricultural, horticultural or forestry machines, or under heading 8436 10 00 as machinery for preparing animal feeding stuffs.

Analysis: The classification turned on the tariff description, the Section and Chapter Notes, and the HSN Explanatory Notes. Heading 8208 specifically covers knives and cutting blades for agricultural, horticultural or forestry machines, while Chapter XVI excludes articles of Chapter 82. The HSN Notes to Heading 82.08 expressly include blades and knives for straw cutters and similar agricultural machines. The HSN Notes to Heading 84.36 also exclude cutting blades and knives for straw cutters. The applicant's reliance on the "parts" principle and user-based classification did not prevail because the goods themselves are cutting blades specifically described in Heading 8208.

Conclusion: The blades are classifiable under heading 8208 40 00 and are liable to GST at 18%, not under heading 8436 10 00.

Ratio Decidendi: Where goods are expressly covered by a specific tariff heading and the HSN Notes support that specific coverage, they cannot be shifted to a more general heading for parts or machinery merely because they are used with a particular machine.

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