Tariff classification by specific heading prevails over residual machinery entries for goods named in Chapter 84.

Tariff classification of water shower, water filter and float wash depended on their specific description and function under Chapter 84, not on their alleged use as parts of paper-making machinery. The Tribunal applied Section Note 2 of Section XVI to hold that goods already covered by a particular heading must be classified under that heading, and rejected reliance on Section Note 3 on composite machines and principal function to move them into the residual paper-making machinery entry. The goods were therefore classifiable under their respective specific headings rather than Heading 8439.90, with the consequence that the demand and penalty based on paper-making machinery classification could not be sustained.

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Issues: Whether water shower, water filter and float wash were correctly classifiable under Heading 84.21 and Heading 84.24, or whether they were to be treated as parts of paper-making machinery classifiable under Heading 8439.90.

Analysis: The dispute turned on the tariff classification of the goods by reference to their function and the relevant section notes. The goods were not shown to be parts used directly in the paper-making machinery itself, and they were specifically described by name within the tariff under the competing headings. Under Section Note 2 of Section XVI, parts which are goods included in a heading of Chapter 84 are to be classified in their respective headings. The Tribunal also held that Section Note 3 of Section XVI, dealing with composite machines and principal function, did not justify shifting goods specifically covered under separate headings into the residual paper-making machinery entry.

Conclusion: The goods were classifiable under their respective specific headings and not under Heading 8439.90.

Final Conclusion: The demand and penalty could not be sustained on the basis of classification under paper-making machinery, and the appeal succeeded with consequential relief.

Ratio Decidendi: Where goods are specifically covered by a tariff heading, they must be classified under that specific heading rather than under a more general or residual heading for machinery parts.

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