Tariff classification of machine saw blades favours the specific heading for saw blades over the general machine cutting-blade entry.

Imported machine saw blades are classified under Heading 8202.99 as blades for saws of all kinds, including blades for machines, rather than under Heading 8208.90 for knives and cutting blades for machines. The tariff distinction turns on the specific coverage of Heading 82.02, which expressly includes saw blades, while Heading 82.08 is directed to knives and cutting blades used in machines or mechanical appliances. HSN Explanatory Notes and Tribunal precedent support classification of machine saw blades under Heading 82.02, so reassessment under that entry was upheld and the claim for Heading 8208.90 failed.

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Issues: Whether imported saw blades used in a machine were classifiable under Heading 82.08 as knives and cutting blades for machines or under Heading 82.02 as blades for saws of all kinds, and whether reassessment under Heading 8202.99 was correct.

Analysis: Heading 82.02 specifically covers hand saws and blades for saws of all kinds, including blades for machines. Heading 82.08 applies to knives and cutting blades for machines or mechanical appliances, but the imported goods were found to be saw blades and not metal cutting shears or similar tools. The HSN Explanatory Note to Heading 82.02 and the cited Tribunal decisions supported the view that machine saw blades fall within Heading 82.02 rather than Heading 82.08.

Conclusion: The correct classification was Heading 8202.99, and the importer's claim to classification under Heading 8208.90 failed.

Final Conclusion: The appeal was rejected because the goods were held to be classifiable under the tariff entry for saw blades rather than the entry for knives and cutting blades for machines.

Ratio Decidendi: Where a tariff heading specifically covers blades for saws of all kinds, including machine saw blades, such goods cannot be shifted to a more general heading for knives and cutting blades for machines.

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