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Issues: Whether motor car seats were classifiable under Chapter Heading 87.08 as claimed by the assessee or under Chapter Heading 94.01 as contended by the Revenue.
Analysis: The dispute turned on the proper tariff classification of motor car seats. The relevant chapter notes and HSN Explanatory Notes were considered, and the earlier Tribunal view on seats used in motor vehicles was followed. Since the goods were admittedly motor car seats, they were treated as seats of a kind used in motor vehicles and not excluded from Chapter 94 merely because of their mode of fixation in the vehicle.
Conclusion: Motor car seats were held classifiable under Chapter Heading 94.01, not under Chapter Heading 87.08, and the Revenue's view was accepted.
Ratio Decidendi: Seats of a kind used in motor vehicles fall within Chapter 94.01 of the Central Excise Tariff Act, 1985 for tariff classification purposes.