Tariff classification of machinery parts under the specific parts heading prevailed over headings for the machines themselves.

Parts and components suitable for use solely or principally with machinery of Heading Nos. 84.25 to 84.30 were held classifiable under Heading No. 84.31, because that heading specifically covers such parts. The Tribunal distinguished Section Note 4 of Section XVI, which applies to complete machines made up of components, from Section Note 2, which governed classification of parts. On that basis, parts specifically described by Heading No. 84.31 could not be shifted to the headings applicable to the machinery itself. The lower authority's classification was found consistent with the tariff description and section notes, and the refund-related challenge failed on merits.

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Issues: Whether parts/components of machinery classifiable under Heading Nos. 84.28 and 84.29 were correctly classifiable under Heading No. 84.31 of the Central Excise Tariff, and whether the appeals challenging the same classification and consequential refund-related rejection could succeed.

Analysis: Heading No. 84.31 specifically covers parts suitable for use solely or principally with machinery of Heading Nos. 84.25 to 84.30, which includes machinery falling under Heading Nos. 84.28 and 84.29. Section Note 4 of Section XVI applies to classification of a machine made up of individual components, whereas the dispute here concerned classification of parts. For parts, Section Note 2 of Section XVI governed the exercise, and the Tribunal found that parts specifically described by Heading No. 84.31 could not be shifted to the headings applicable to the machines themselves. The reasoning adopted by the lower authority was found consistent with the tariff description and section notes.

Conclusion: The parts/components were correctly classifiable under Heading No. 84.31, and the challenge to that classification failed.

Final Conclusion: The tariff heading specifically covering parts for the relevant machinery governed the dispute, so both appeals failed on merits.

Ratio Decidendi: Where a tariff heading specifically covers parts suitable for use solely or principally with identified machinery, those parts must be classified under that specific heading and not under the headings applicable to the machinery itself; the section note for complete machines does not control the classification of parts.

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