Classification of bulldozer parts turned on model-specific use, with invoices and part numbers supporting heading 8431.49.

Seal assembly and dust seal were classified as parts suitable solely and principally for use with bulldozers under sub-heading 8431.49, not as residual goods under sub-heading 8485.90. Classification was supported by the purchase orders, invoices, and part numbers linking the goods to specific bulldozer or crawler tractor models, while the Revenue produced no contrary material to show they were not meant for the claimed model. The absence of embossed part numbers on the goods, by itself, was insufficient to alter classification. On the available material, the goods were treated as components for manufacture of bulldozers under Heading 84.29, and the assessee's appeal succeeded.

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Issues: Whether the seal assembly and dust seal were classifiable under sub-heading 8431.49 as parts suitable solely and principally for use with bulldozers falling under Heading 84.29, or under sub-heading 8485.90.

Analysis: The purchase order and invoices showed that the goods were ordered and supplied according to part numbers for specific models of bulldozers or crawler tractors. The Revenue did not place material on record to show that the goods were not meant for the particular model claimed. Classification was altered only on the basis of doubt arising from the absence of embossed part numbers on the goods. On the material available, the imported goods were shown to be principally and solely for use in the manufacture of bulldozers covered by Heading 84.29.

Conclusion: The goods were classifiable under sub-heading 8431.49 and not under sub-heading 8485.90; the appeal succeeded in favour of the assessee.

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