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Issues: Whether Servo Brake Valve, Shut Off Cock, and their parts were classifiable under Heading 84.81 as taps, cocks, valves and similar appliances, or under Heading 87.08 as parts and accessories of motor vehicles.
Analysis: Heading 84.81 covers taps, cocks, valves and similar appliances used on pipes, tanks and similar systems to regulate the flow or pressure of fluids, and the heading continues to apply even where such devices are specialized for use in a particular machine or vehicle. The functional description of the goods showed that the servo brake valve and shut off cock were used in pipes to regulate the flow of air, and their principal function was that of a valve. The classification was therefore governed by the nature and dominant function of the component. Section Note 2(e) of Section XVII excluded articles of Heading 84.81 from treatment as motor vehicle parts, and the notes to Heading 87.08 required that the goods must not be so excluded. On that footing, the goods could not be classified as motor vehicle parts merely because they were used in motor vehicles.
Conclusion: Servo Brake Valve, Shut Off Cock, and their parts were correctly classifiable under Heading 84.81 and not under Heading 87.08, and the departmental appeal failed.
Ratio Decidendi: An article whose principal function is to regulate fluid flow as a valve remains classifiable under Heading 84.81, even if used in a motor vehicle, and it cannot be treated as a motor vehicle part where Section XVII expressly excludes articles of that heading.
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