Steam turbine rotor classification turns on specific tariff heading for turbine parts, not general transmission shaft treatment.

A steam turbine rotor designed solely for use in a steam turbine was classifiable under the specific heading for steam turbines and their parts, not under the general heading for transmission shafts. Commercial nomenclature could not override the tariff description, and Section Note 2 of Section XVI supported classification of parts under the heading applicable to the machine itself. The rotor's shaft-like features and internal transmission of mechanical energy did not make it a transmission shaft for tariff purposes. The text also notes that the filter classification was accepted.

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Issues: Classification of a steam turbine rotor for tariff purposes: whether it falls under Tariff Heading 8483.00 as a transmission shaft or under Tariff Heading 84.06 as a steam turbine part.

Analysis: The rotor was undisputedly designed for and used solely in a steam turbine, with no material to show use in any other machine or equipment. In tariff classification, commercial nomenclature is relevant but remains subordinate to the tariff description. Since Heading 84.06 specifically covers steam turbines and their parts, and Section Note 2 of Section XVI supports classification of parts under the specific heading applicable to the machine, the rotor could not be treated as a transmission shaft under Heading 8483.00 merely because it contained shaft-like elements or transmitted mechanical energy within the turbine assembly.

Conclusion: The rotor was correctly classifiable under Tariff Heading 84.06 and not under Tariff Heading 8483.00.

Final Conclusion: The appeal succeeded on the rotor classification issue, while the filter classification stood accepted, resulting in the matter being disposed of by upholding the assessee's classification for the rotor.

Ratio Decidendi: A turbine rotor meant solely for use in a steam turbine is classifiable under the specific heading for steam turbines and their parts, and not under a more general heading for transmission shafts.

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