Tariff classification of grab buckets and cram shells as parts under Heading 84.31 upheld over complete machinery classification.

Grab buckets and cram shells were held classifiable as parts under Heading 84.31, not as complete lifting, handling, loading or unloading machinery under Heading 84.28. The classification turned on the product description and the tariff scheme: the goods were not complete machinery and could not function independently without being fixed to other lifting and handling equipment. Section Note 2(A) of Section XVI and the HSN Explanatory Notes supported treatment of lifting grabs, buckets and similar goods as parts suitable for use solely or principally with such machinery. Revenue's classification under Heading 84.28 was therefore rejected and classification under Heading 84.31 upheld.

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Issues: Whether grab buckets and cram shells were classifiable as complete lifting, handling, loading or unloading machinery under Heading No. 84.28, or as parts suitable for use solely or principally with such machinery under Heading No. 84.31.

Analysis: Heading No. 84.28 covers complete machinery for lifting, handling, loading or unloading, while Heading No. 84.31 covers parts suitable for use solely or principally with machinery of Heading Nos. 84.25 to 84.30. On the product description, the goods were not complete machinery and could not perform their function independently without being fixed with other lifting and handling equipment. The scheme of the tariff, including Section Note 2(A) of Section XVI and the HSN Explanatory Notes, specifically supported classification of lifting grabs, buckets and similar goods as parts under Heading No. 84.31.

Conclusion: The goods were correctly classifiable under Heading No. 84.31 and not under Heading No. 84.28, and the Revenue's classification was upheld.

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