Customs classification of integral pump bearing turned on proof that the item was a bearing in trade and law.

Imported water pump bearing with integral shaft bearing part No. FPS-348 was considered for classification under Heading 84.13 as a specially designed pump part or under Heading 84.82 as a bearing. The Tribunal found no new material to displace its earlier view that the item was a combination of a shaft and bearing, not a bearing simpliciter. The Revenue failed to prove, by evidence, that the goods were known in trade as ball or roller bearings or used beyond water pumps. On that basis, classification under Heading 84.13 was upheld and the refund claim remained admissible.

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Issues: Whether the imported water pump bearing with integral shaft bearing part No. FPS-348 was classifiable under Heading 84.13 as a part specially designed for use in water pumps, or under Heading 84.82 as a bearing, and whether the refund claim based on the former classification was admissible.

Analysis: The imported goods had earlier been held in the respondent's own case to be a combination of a shaft and a bearing and not a bearing simpliciter. No new factual material or persuasive argument was produced to displace the earlier view adopted by the Tribunal and the Government of India. The Revenue relied on catalogue material and general references to other applications, but did not adduce evidence showing that the particular goods in question were known in trade as ball or roller bearings or that they had use in industries other than water pumps. The burden to justify the proposed classification under Heading 84.82 lay on the Revenue, and that burden was not discharged.

Conclusion: The goods were not classifiable under Heading 84.82 and were rightly treated as falling under Heading 84.13. The refusal to interfere with the appellate order allowing the refund claim was justified, and the Revenue's challenge failed.

Ratio Decidendi: Where the Revenue seeks to classify an imported item under a tariff heading for bearings, it must establish by evidence that the goods answer that description in trade and in law; absent such proof, a combined part specially designed for a specific machine is not to be treated as a bearing simpliciter.

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