Functional classification of mine machinery favored Heading 84.22 over motor vehicle treatment under the Customs Tariff.

Load haul dump machinery used in mines for loading, transporting and dumping ore and rocks was classifiable as lifting, handling, loading or unloading machinery under Heading 84.22, because its essential function was a specialised loading and handling operation with a built-in lifting or loading arrangement. It was not a normal motor vehicle for transport of persons, goods or materials under Heading 87.02, as its design and use were confined to mine working spaces. The equipment's functional character, together with the Revenue's earlier acceptance of the same classification, supported classification under Heading 84.22. The Revenue's challenge failed.

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Issues: Whether the Load Haul Dump machine and its components were classifiable under Heading 84.22 of the Customs Tariff Act, 1975 as lifting, handling, loading or unloading machinery, or under Heading 87.02 as a motor vehicle for transport of persons, goods or materials.

Analysis: The machine was designed for loading, transporting and dumping ore and rocks in mines and for movement in confined working spaces. Its essential function was that of a specialised loading and handling machine with built-in lifting or loading arrangement, and it was not a normal four-wheeled transport vehicle in the sense contemplated by Heading 87.02. The functional character of the equipment and the earlier acceptance of the same classification by the Revenue supported classification under Heading 84.22.

Conclusion: The machine was correctly classifiable under Heading 84.22 and not under Heading 87.02; the Revenue's challenge failed.

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