Tariff classification of calender rolls: specific heading for calendering machines prevails over parts-of-machine treatment.

Calender rolls used in the calendering section of paper-making machinery were held classifiable under Heading 8420 as calendering or rolling machines, not under Heading 8439 as parts of paper-making machinery. Although the rolls could form part of a Fourdrinier paper-making machine, Note 2(a) of Section XVI required classification under the specific tariff entry, and the HSN notes to Heading 8439 expressly excluded calender rolls. The specific heading therefore prevailed over the general claim that the goods were parts of the principal machine, and the departmental classification was upheld.

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Issues: Whether calender rolls imported for use in the calendering section of paper-making machinery were classifiable as parts of paper-making machinery under Heading 8439 or under Heading 8420 as calendering or rolling machines.

Analysis: The goods were admittedly rolls used in the calendering section of the machine and could form part of a Fourdrinier paper-making machine. However, their classification as parts of the principal machine could not be accepted where Note 2(a) of Section XVI required the goods to be classified according to the specific tariff entry. The tariff scheme specifically covered calendering machines under Heading 8420, and the HSN notes under Heading 8439 expressly excluded calender rolls from that heading. The reasoning was also consistent with earlier tribunal authority dealing with swimming rolls and accessories of calender stock of paper.

Conclusion: The goods were correctly classifiable under Heading 8420 and not under Heading 8439, and the classification adopted by the department was upheld.

Final Conclusion: The appeal failed on the tariff classification question, and the lower order was sustained.

Ratio Decidendi: Where goods are specifically covered by a tariff heading and are excluded by the relevant notes and HSN explanatory notes from classification as parts of another machine, the specific heading governs over the general claim that the goods are parts of the principal machine.

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