Tariff classification of heat exchanger tubes follows the specific heading for seamless steel tubes, not end use as machine parts.

Seamless steel tubes specially designed for heat exchangers were classified under Chapter 73, because the tariff scheme and HSN specifically covered tubes and pipes suitable for such use in Heading 73.04. The explanatory notes distinguished identifiable parts of goods from parts of general use, and the Chapter 84 notes excluded metal tubes or pipes not otherwise worked from treatment as identifiable parts of heat exchangers. End use as a component of another machine did not override the specific tariff entry for the goods themselves. The classification under Chapter 73 was therefore sustained and the competing claim under Chapter 84 was rejected.

---

---

Issues: Whether seamless steel tubes specially designed for use in heat exchangers were classifiable as parts of heat exchangers under Chapter 84 or as seamless steel tubes under Chapter 73.

Analysis: The goods were specifically described in Chapter 73, and the explanatory notes under Section XV treated identifiable parts of articles differently from parts of general use. The Harmonised System Nomenclature expressly included tubes and pipes suitable for use in heat exchangers within Heading 73.04, while the notes under Chapter 84 excluded metal tubes or pipes not otherwise worked from treatment as identifiable parts of goods of that chapter. The tariff scheme therefore required classification according to the specific heading applicable to the goods themselves, rather than by reference to the intended end use.

Conclusion: The goods were correctly classifiable under Chapter 73 and not under Chapter 84; the classification urged by the appellant was rejected.

Final Conclusion: The appeals failed and the customs classification adopted by the lower authorities was sustained.

Ratio Decidendi: Where tariff notes specifically describe goods under one heading, and the HSN expressly includes such goods in that heading, end use as a component of another machine does not override classification under the specific tariff entry.

---