Classification of wood-working machine knives under Heading 9806 denied customs concession due to interchangeability exclusion.

Wood peeling knives designed exclusively for use with wood-working machines were treated as parts of machinery under Chapter 84 and classified under sub-heading 9806. The Tribunal followed the earlier Larger Bench view that such machine parts fall within Heading 98.06, and held that any possible treatment of the goods as tools under Chapter 82 did not secure notification relief because the express proviso excluded interchangeable tools. On that basis, the knives used with wood-working machines under Heading 84.65 were held ineligible for the claimed concessional customs treatment, and the classification under sub-heading 9806 was maintained.

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Issues: Whether wood peeling knives designed for exclusive use with wood-working machines were classifiable under sub-heading 8208.20 or under sub-heading 9806, and whether they were entitled to the benefit of the relevant customs notifications.

Analysis: The Tribunal applied the earlier Larger Bench view that parts of machinery falling under Chapter 84 were classifiable under Heading 98.06. It also held that, even if such goods could otherwise be regarded as tools under Chapter 82 for notification purposes, they were excluded from the benefit of the notification by the express proviso dealing with interchangeable tools. On that basis, the disputed knives, being designed for use with wood-working machines covered by Heading 84.65, fell within sub-heading 9806 and were not eligible for the claimed concessional treatment.

Conclusion: The goods were correctly classified under sub-heading 9806, and the appeal was rejected.

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