HSN-based tariff classification: grease oil and lubricating pumps fall under machinery heading, not hand-held tools.

Grease oil and lubricating pumps were classified under Heading 8424.00 rather than Heading 8467.00 because Chapter 84 was read with the HSN explanatory notes, and the equipment as a whole was found to be heavy, not hand-held, and arranged as an integral tank-and-pump system. The fact that the administering gun could be held in hand did not change the classification of the complete equipment, since the relevant tariff heading covered the full lubricating apparatus rather than a hand-held tool. The classification under Heading 8424.00 was therefore preferred over Heading 8467.00.

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Issues: Whether grease oil and lubricating pumps were classifiable under Heading 8424.00 or under Heading 8467.00 of the Central Excise Tariff Act, 1985.

Analysis: Chapter 84 being aligned to the Harmonised System of Nomenclature, the HSN explanatory notes were relied upon for resolving the tariff dispute. The equipment, taken as a whole, was found to be heavy and not capable of being held in hand. The lubricant was stored in a steel drum under high pressure and the system consisted of an integral tank and pump. Merely because the administering gun could be held in hand did not justify classification of the entire equipment under the heading meant for hand-held tools.

Conclusion: The grease oil and lubricating pumps were held classifiable under Heading 8424.00 and not under Heading 8467.00, in favour of the assessee.

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