Classification of specially designed electric transformers under the specific transformer heading, not as furnace parts, was upheld.

Electric transformers cleared separately for use with an electric arc furnace were classifiable under Heading 85.04 as transformers, not as parts of the furnace under Heading 85.14. The goods were identifiable in their own right and were cleared under separate excise documents, and the presence of a specific tariff heading for electrical transformers meant Section Note 2(a) governed classification. Section Note 4 of Section XVI did not displace that specific heading merely because the transformers were specially designed to operate with the furnace. HSN explanatory notes also supported classification of specially designed transformers under the transformer heading. The transformers were therefore correctly classified under Heading 85.04, and the appeal failed.

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Issues: Whether electric transformers cleared separately for use with an electric arc furnace were classifiable under Heading 85.04 as transformers or as parts of the furnace under Heading 85.14 by applying Section Note 4 of Section XVI.

Analysis: The goods cleared from the factory were transformers under separate excise documents and were therefore identifiable as transformers in their own right. A specific tariff heading existed for electrical transformers under Heading 85.04. The Tribunal held that where a product is clearly classifiable under its own specific heading, Section Note 2(a) applied and excluded resort to Section Note 4. The fact that the transformers were specially designed to work with the furnace did not alter their classification, and the HSN explanatory notes supported classification of specially designed transformers under the heading for transformers.

Conclusion: The transformers were correctly classified under Heading 85.04 and not as parts of the electric arc furnace. The appeal failed.

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