Tariff classification of piling rigs as machinery parts upheld under Heading 84.31, not structural goods.

Piling rigs were held not to be structures or parts of structures under Heading 73.08 because their nature and function showed they formed an integral part of pile-driving machinery. Applying the technical literature, HSN Explanatory Notes, and Section XVI classification principles, the goods were treated as parts suitable for use solely or principally with machinery of Heading 84.30. Section Note 2(b) required classification with the machine rather than as structural goods, so the correct classification was under Heading 84.31 and the Revenue's classification was sustained.

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Issues: Whether piling rigs were classifiable as structures or parts of structures under Heading 73.08, or as parts suitable for use solely or principally with machinery of Heading 84.30 under Heading 84.31.

Analysis: The competing tariff entries were examined with reference to the nature and function of the goods, the technical literature, the HSN Explanatory Notes, and the classification principles in Section XVI. The goods were found to form an integral part of the pile driver and not a completed structure of the kind covered by Heading 73.08. The Explanatory Notes also supported exclusion of machinery parts from Heading 73.08. Since pile drivers were specifically covered under Heading 84.30 and the goods were suitable for use solely or principally with that machinery, Section Note 2(b) required classification with the machine rather than as structural goods.

Conclusion: The goods were correctly classifiable under Heading 84.31 and not under Heading 73.08; the classification in favour of the Revenue was sustained.

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