Specific tariff classification for tanker bodies prevails over general motor vehicle heading, placing the goods under Heading 8707.

M.S. tank bodies manufactured for transport vehicles were held classifiable under Heading 8707 rather than Heading 8704. The classification dispute was resolved by applying the principle that a specific tariff entry for tanker bodies or similar vehicle bodies prevails over the general motor vehicle heading. Prior Tribunal and Supreme Court rulings on tankers mounted on duty-paid chassis supported that specific treatment. The goods were therefore placed under Heading 8707, and the assessee received the resulting classification benefit.

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Issues: Whether M.S. tank bodies manufactured by the assessee were classifiable under Heading 8707 or under Heading 8704.

Analysis: The dispute turned on the proper tariff classification of tanker bodies and related vehicle bodies. Reliance was placed on prior Tribunal and Supreme Court rulings which treated tankers mounted on duty-paid chassis as falling under Heading 8707. The reasoning accepted that the article in question was appropriately covered by the specific entry for such goods rather than by the residual motor vehicle heading.

Conclusion: The goods were classifiable under Heading 8707 and not under Heading 8704, in favour of the assessee.

Final Conclusion: The appeal succeeded and the assessee obtained the consequential relief flowing from the corrected classification.

Ratio Decidendi: Where a specific tariff entry covers tanker bodies or similar bodies for transport vehicles, that specific classification prevails over the general motor vehicle heading.

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