HSN Explanatory Notes supported classification of couplings as shaft couplings under Tariff Heading 84.83.

Goods described as various couplings were treated as classifiable under Tariff Heading 84.83 as shaft couplings rather than under Tariff Heading 84.85 as parts of machinery. Because the tariff heading was aligned with the HSN, the HSN Explanatory Notes were given high persuasive value in determining the scope of shaft couplings. On that basis, the couplings were held to fall within Heading 84.83, and the residuary classification was not accepted.

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Issues: Whether the goods described as various couplings were classifiable under Tariff Heading 84.83 as shaft couplings or under Tariff Heading 84.85 as parts of machinery.

Analysis: The goods were not described as shaft couplings in the purchase orders, but the scope of shaft couplings was to be understood with reference to the HSN Explanatory Notes. Since the tariff heading is based on the HSN, the Explanatory Notes were treated as having high persuasive value. On that basis, the couplings in question were regarded as falling within the scope of Tariff Heading 84.83 rather than the residuary heading relied upon by the appellant.

Conclusion: The classification under Tariff Heading 84.83 was upheld and the appeal was dismissed.

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