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Issues: Whether the disputed bolts, nuts and related automobile components were classifiable as parts and accessories of motor vehicles under Heading 8708.00 or as threaded articles under Heading 7318.10.
Analysis: The classification dispute had to be resolved with reference to the scheme of the Central Excise Tariff Act, 1985 and the relevant Section Notes. Section Note 2 of Section XVII excludes parts of general use, and Section Note 3 of Section XVII requires parts and accessories to be classified according to their principal use when they are suitable for use solely or principally with articles of Chapters 86 to 88. The record contained product catalogues, certificates, affidavits and other material showing that the goods were specially designed for identifiable motor vehicle models, were treated by buyers as original equipment, and had functional utility beyond mere fastening. The earlier decisions under the erstwhile tariff were treated as distinguishable because the present tariff scheme was materially different.
Conclusion: The goods were held to be more appropriately classifiable under Heading 8708.00 and not under Heading 7318.10, and the Revenue's classification claim failed.
Ratio Decidendi: Goods specially designed for motor vehicles, supported by evidence of commercial understanding and principal use, are classifiable as motor vehicle parts and accessories unless they fall within the excluded category of parts of general use.