Specific tariff heading for bearings prevails over end-use classification for water pump components.

Bearings supplied for water pumps were held to fall under the specific tariff entry for ball or roller bearings, because the goods were bearings simpliciter and not machinery parts incorporating bearings. The end-use argument based on water pump application did not override the specific description in Heading 84.82. Classification under Heading 87.08 was therefore rejected, and Heading 84.82 applied.

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Issues: Whether bearings for water pumps were classifiable under Heading 84.82 of the Central Excise Tariff or under Heading 87.08 on the basis of end use.

Analysis: The product in dispute was itself a bearing. Heading 84.82 specifically covered ball or roller bearings, whereas the relied-upon HSN note excluded only machinery parts incorporating such bearings. Since the goods were not machinery parts but bearings simpliciter, the specific tariff heading applicable to bearings governed the classification. The plea that classification should follow the intended use of the water pumps did not displace the specific tariff description.

Conclusion: The goods were correctly classifiable under Heading 84.82 and not under Heading 87.08.

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