Classification of chaff cutter blades falls under Heading 8208 as cutting blades, not as parts of animal feed machinery.

Blades cleared as spare parts for chaff cutter machines were held classifiable under Heading 8208 40 00 as knives and cutting blades for agricultural machinery, not under Heading 8436 10 00 or 8436 80 90 as parts of machinery for preparing animal feeding stuffs. The classification was determined by the wording of the headings, the relevant section and chapter notes, and the explanatory notes, which specifically include blades for straw cutters under Heading 8208 and exclude such cutting blades from Heading 8436. As Chapter 82 articles are excluded from Section XVI, the general interpretive rules could not override the specific heading. GST therefore applies at 18%.

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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 / 8436 80 90 as parts or machinery for preparing animal feeding stuffs.

Analysis: The classification had to be determined primarily from the terms of the heading read with the relevant section and chapter notes. Heading 8208 specifically covers knives and cutting blades for agricultural, horticultural or forestry machines, while Heading 8436 covers agricultural machinery and machinery for preparing animal feeding stuffs. The explanatory notes to Heading 8208 expressly include blades and knives for root cutters and straw cutters. The explanatory notes to Heading 8436 specifically exclude cutting blades and knives for straw cutters and similar machines, which reinforces the specific coverage under Heading 8208. Section XVI notes did not displace this result because articles of Chapter 82 are excluded from that section, and the general rules of interpretation cannot override a clear specific heading. Applying these principles, the blades manufactured for chaff cutters are not classifiable as parts under Heading 8436 merely because they are used in agricultural machinery.

Conclusion: The blades are classifiable under Heading 8208 40 00 and are liable to GST at 18%, not under Heading 8436 10 00 or 8436 80 90.

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