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Issues: Classification of the base frame for piercing mill gear box motor under the appropriate tariff heading.
Analysis: The base frame was used only as a support for the gear box and motor fitted to the tube rolling mill and those components were complete without it. Heading No. 85.03 was held inapplicable because it covered parts suitable for use solely or principally with machines of Heading Nos. 85.01 and 85.02, whereas the motors and related equipment were not incomplete without the base frame. On the facts, the wider coverage of Heading No. 84.55, relating to metal rolling mills and rolls thereof, was found to be the more appropriate classification.
Conclusion: The goods were correctly classifiable under Heading No. 84.55 and not under Heading No. 85.03; the Revenue's appeal was rejected.