Functional character governs tariff classification of vehicle seats, with two-wheeler seats placed under vehicle parts and another issue remanded.

Bare seats for two-wheelers were treated as vehicle parts by their essential functional character and the applicable tariff context, so they fell under Chapter Heading 87.14 rather than as polyurethane foam articles. For bare seats used in motor vehicles other than two-wheelers, a fresh classification question arose because a new contention under Heading 94.01 had not been examined below; the matter therefore required de novo determination on remand, with the adjudicating authority to decide whether the goods belonged under 87.08 or 94.01. The stated principle was that classification turns on functional character and tariff notes, and unexamined factual questions may justify remand.

---

---

Issues: (i) Whether bare seats used for two-wheelers were classifiable under Chapter Heading 87.14. (ii) Whether bare seats used for motor vehicles other than two-wheelers were classifiable under Chapter Heading 87.08 or Chapter Heading 94.01, warranting remand for fresh determination.

Issue (i): Whether bare seats used for two-wheelers were classifiable under Chapter Heading 87.14.

Analysis: The functional character of the product was that of a seat fitted to a scooter or motor cycle. Seats of this kind were treated as parts of vehicles and not as articles of polyurethane foam. The relevant tariff context supported classification with vehicle parts rather than under the foam heading.

Conclusion: Yes. Bare seats used for two-wheelers were correctly classifiable under Chapter Heading 87.14, in favour of the assessee.

Issue (ii): Whether bare seats used for motor vehicles other than two-wheelers were classifiable under Chapter Heading 87.08 or Chapter Heading 94.01, warranting remand for fresh determination.

Analysis: For seats used in motor vehicles other than two-wheelers, the Tribunal noted that a new contention had been raised that they could fall under Heading 94.01. Since that point had not been examined by the lower authority, and the correct classification depended on the factual use and the relevant tariff notes, the matter required reconsideration by the adjudicating authority.

Conclusion: The question was left for de novo determination on remand, with the lower authority to decide whether the goods fell under 87.08 or 94.01.

Final Conclusion: The appeal succeeded only to the extent of securing classification of two-wheeler seats under Chapter Heading 87.14, while the remaining classification dispute was sent back for fresh decision.

Ratio Decidendi: Goods are to be classified according to their essential functional character and the applicable tariff notes, and where a new classification basis requires factual examination not undertaken below, remand for de novo consideration is appropriate.

---