Specific tariff classification prevails where electromagnetic clutches are not constituent parts of air-conditioning machinery.

Electro magnetic clutches imported for car air-conditioning were held classifiable under sub-heading 8505.20 as electro magnetic clutches, not under 9806.00 as parts of air-conditioning machinery. The goods transmitted power to engage or disengage the compressor, but they were not constituent parts of the crankshaft or compressor itself. Note 4 to Section XVI did not apply because the components did not collectively perform a clearly defined function as a machine combination. The distinction between a part and an accessory supported classification under the specific tariff heading, and the Revenue's challenge failed.

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Issues: Whether electro magnetic clutches imported for car air-conditioning were classifiable under sub-heading 8505.20 as electro magnetic clutches or under sub-heading 9806.00 as parts of air-conditioning machinery, and whether Note 4 to Section XVI altered that position.

Analysis: The imported goods were specifically covered by Heading 85.05, sub-heading 8505.20. Their role was to transmit power between the engine and the compressor and to engage or disengage the compressor, but they were not themselves part of either the crankshaft or the compressor. Note 4 to Section XVI applied where individual components of a machine or combination of machines contributed together to a clearly defined function; that situation was not present here. Since the goods were not parts of the air-conditioning machine, classification under 9806.00 was not justified, and the distinction between a part and an accessory supported the view taken by the appellate authority.

Conclusion: The goods were correctly classifiable under sub-heading 8505.20 and not under sub-heading 9806.00, and the Revenue's challenge failed.

Final Conclusion: The appellate authority's classification was upheld and the Revenue's appeal was rejected.

Ratio Decidendi: A goods item specifically described in a tariff heading is to be classified under that specific heading when it is not a constituent part of the machine claimed by the Revenue, and a mere functional connection with the machine does not make it a part for classification purposes.

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