Specific tariff heading prevails over machine-part classification, while exemption as isolation valves was remanded for reconsideration.

Valves specifically covered by Heading 84.81 were required to be classified under that heading rather than as parts of a steam power unit, because goods described in a specific tariff entry cannot be placed under a more general machine-part heading merely by intended use. The imported parallel slide valves were therefore classified under sub-heading 8481.80. The separate claim for exemption under Notification No. 60/87 as isolation valves could not be decided on the existing record, so it was sent back for fresh consideration after hearing the appellants.

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Issues: (i) Whether the imported parallel slide valves were classifiable under Heading 84.81, sub-heading 8481.80 of the Customs Tariff or as parts of a steam power unit under the claimed heading. (ii) Whether the appellants were entitled to exemption under Notification No. 60/87 as isolation valves.

Issue (i): Whether the imported parallel slide valves were classifiable under Heading 84.81, sub-heading 8481.80 of the Customs Tariff or as parts of a steam power unit under the claimed heading.

Analysis: The heading relating to steam turbines was treated as inapplicable to the imported item as a part of steam turbines, because valves are specifically covered as a separate tariff item under Heading 84.81. Applying the General Explanatory Notes to Section XVI and Note 2 to Section XVI of the Customs Tariff, parts which are themselves articles covered by a specific heading are classified in that heading. Since the imported goods were valves and not excluded from the scope of Heading 84.81, they could not be classified under the heading claimed by the importers.

Conclusion: The goods were correctly classified under Heading 84.81, sub-heading 8481.80, against the assessee.

Issue (ii): Whether the appellants were entitled to exemption under Notification No. 60/87 as isolation valves.

Analysis: No finding had been recorded by the lower authorities on this claim, and the material on record was insufficient to determine conclusively whether the imported valves were isolation valves. The exemption claim therefore required fresh examination after giving the appellants an opportunity of being heard.

Conclusion: The exemption claim was remanded for reconsideration in favour of the assessee.

Final Conclusion: The classification made by the lower authority was sustained, but the separate exemption claim was sent back for fresh decision on merits.

Ratio Decidendi: Where a goods entry is specifically covered by a tariff heading, it must be classified in that heading rather than as a part of another machine or apparatus, even if it is designed for use with that machine.

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