Classification of trailer fire pumps turns on whether they are complete fire-fighting appliances or mere liquid pumps.

Trailer fire pumps mounted on a chassis and fitted with an engine were treated as complete mechanical appliances for projecting jets of water for fire fighting, rather than mere pumps for liquids. Heading 84.24, covering mechanical appliances for projecting, dispersing or spraying liquids or powders, was regarded as the more specific classification and therefore applicable in place of Heading 84.13. The classification was thus resolved in favour of Revenue under Heading 84.24.

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Issues: Whether trailer fire pumps mounted on a chassis and fitted with an engine were classifiable under Heading 84.24 as mechanical appliances for projecting, dispersing or spraying liquids or powders, or under Heading 84.13 as pumps for liquids.

Analysis: The goods were found to be complete trailer fire pumps mounted on a chassis and fitted with an engine. On that basis, they were not mere pumps for liquids but complete mechanical appliances for projecting jets of water for fire fighting. Heading 84.24 specifically covers mechanical appliances for projecting, dispersing or spraying liquids or powders, and was held to be more appropriate than Heading 84.13.

Conclusion: The goods were held classifiable under Heading 84.24 and not under Heading 84.13, in favour of the Revenue.

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