Tractor parts classification turns on Section Notes and Chapter Notes, with gears and shafts treated as vehicle parts under heading 8708.

Gears and shafts used principally in tractors were classified under heading 8708 as tractor parts because classification had to follow the heading terms together with the relevant Section and Chapter Notes. Section Note 1(k) to Section XVI excluded articles of Section XVII, so Note 2(a) of Section XVI could not override that exclusion unless Section XVII was first found inapplicable. The goods were not shown, on evidence, to be integral parts of engines or motors, and the specific reference to gears and shafts in heading 8483 did not displace the statutory notes. HSN extracts were treated as consistent with the distinction between internal engine parts and vehicle transmission parts.

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Issues: Whether gears and shafts used principally in tractors were classifiable under tariff heading 8483 as parts specifically covered by the tariff, or under tariff heading 8708 as tractor parts, having regard to the Section Notes, Chapter Notes and Interpretative Rules under the Central Excise Tariff Act, 1985.

Analysis: Classification had to be determined first by the terms of the headings and the relative Section Notes and Chapter Notes. Section Note 1(k) of Section XVI excluded articles of Section XVII, and therefore Note 2(a) of Section XVI could be invoked only after determining whether Section XVII applied. The goods were admittedly parts used principally in tractors, and the Revenue did not establish with evidence that they were integral parts of engines or motors so as to attract the exclusion in Section Note 2(e) of Section XVII. The claim that heading 8483 must prevail merely because it specifically mentioned gears and shafts was rejected in the face of the statutory notes and the finding that the goods were not shown to be engine parts. The Tribunal also noted that the HSN extracts supported the distinction between internal engine parts and transmission parts used with vehicles.

Conclusion: The gears and shafts were not shown to be integral parts of engines, and heading 8708 applied. The Revenue's classification claim failed.

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