Classification turns on true function of goods; shafts used in a fan section were not transmission shafts and fell under Heading 8414.99.

Classification of the shafts depended on their true nature and function, not the bare heading description. The record showed tapered ends, a bearing and pulley, connection to a belt and motor, and rotation of impellers as part of the fan section, while the Revenue led no evidence that the goods functioned as transmission shafts within Heading 8483. Applying the HSN Notes, the tribunal held that Heading 8483 covers mechanical parts used to transmit power, and that description was not established here. The shafts were therefore correctly classified under Heading 8414.99 as parts of a fan section, and the contrary classification was rejected.

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Issues: Whether the shafts manufactured by the appellants were classifiable under Heading 8483 as transmission shafts or under Heading 8414 as parts of a fan section.

Analysis: The classification adopted below proceeded only on the description of the heading without identifying the nature and function of the goods. The record showed that the shafts had tapering ends, carried a bearing and pulley, were connected to a belt and motor, and rotated impellers as part of the fan section. There was no rebuttal from the Revenue to this description or to the appellants' assertion that the goods were not transmission shafts in the sense contemplated by Heading 8483. The HSN Notes under Heading 8483 contemplate mechanical parts used in transmission of power from an external unit or internal parts used to transmit power within a machine, and the Revenue led no evidence to show that the impugned shafts answered that description.

Conclusion: The shafts were not classifiable under Heading 8483 and were correctly classifiable under Heading 8414.99. The appeal succeeded and the impugned order was set aside.

Ratio Decidendi: Classification must follow the true nature and function of the goods, and a heading for transmission shafts cannot be applied in the absence of evidence that the goods actually perform that transmission function.

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