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Issues: Whether electric horns manufactured for use in two-wheelers and four-wheelers are classifiable under Chapter 87 as motor vehicle parts or under Heading 85.12 as electrical signalling equipment.
Analysis: The dispute turned on the effect of Section Note 2(f) of Section XVII, which excludes articles falling under Chapter 85 from Section XVII. The goods in question were electric horns, and the specific tariff description in Heading 85.12 covered electrical signalling equipment including horns. In view of the specific note and the more specific tariff entry, the functional character approach relied upon by the assessee did not displace the classification mandated by the tariff structure.
Conclusion: The goods were correctly classified under Heading 85.12 and not under Chapter 87.
Final Conclusion: The appeal failed and the classification adopted by the lower appellate authority was upheld.
Ratio Decidendi: Where a specific section note excludes goods from a chapter and a specific tariff heading squarely covers the goods, classification must follow the specific heading rather than the general chapter describing the end use of the goods.