Specific tariff heading for machine parts prevails over general machine classification where the goods are expressly covered.

Parts suitable for use solely or principally with machinery of Heading 84.28 were held classifiable under the specific parts heading, Heading 84.31, because Section Note 2(a) of Section XVI requires classification under the heading that expressly covers the goods. Once the parts fall within Heading 84.31, the general rule under Section Note 2(b) cannot be used to classify them with the parent machine. The distinction between parts and components did not change the tariff outcome, as the specific heading governed the classification.

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Issues: Whether parts suitable for use solely or principally with machinery classifiable under Heading 84.28 of the Central Excise Tariff Act, 1985 were to be classified under Heading 84.28 or under the specific parts heading, Heading 84.31.

Analysis: Section Note 2(a) of Section XVI requires parts specifically covered by a heading to be classified under that specific heading. Heading 84.31 expressly covers parts suitable for use solely or principally with machinery of Heading 84.28. Therefore, once the parts are brought within Heading 84.31, resort to the general rule of classifying them with the machine under Section Note 2(b) is not available. The distinction sought between parts and components did not alter the classification, as the specific tariff heading governed the issue.

Conclusion: The parts were correctly classifiable under Heading 84.31 and not under Heading 84.28, and the appeal failed.

Final Conclusion: The tariff scheme treated the disputed items as separately classifiable parts under the specific heading, leaving no basis to classify them with the parent machinery.

Ratio Decidendi: Where a tariff heading specifically covers parts suitable for use solely or principally with named machinery, those parts must be classified under the specific parts heading and not with the machine under the general classification rule.

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