Railway coach-specific aluminium tanks fall under Heading 8607, as coach fabrication under Chapter 86 prevails over general classification.

Aluminium water tanks manufactured solely to railway drawings and technical specifications for fitment in railway coaches are treated as part of the coach under Chapter Note 2 to Chapter 86. On that basis, they are more specifically classifiable under Heading 8607 rather than Heading 7611. The analysis is supported by the Board's circular and cited Tribunal decisions, which align with coach-specific fabrication being governed by the railway coach heading.

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Issues: Whether aluminium water tanks manufactured to railway drawings and technical specifications were classifiable under Heading 8607 or under Heading 7611.

Analysis: The goods were manufactured solely for fitment in railway coaches according to railway drawings and specifications. In view of Chapter Note 2 to Chapter 86, goods so fabricated for use in coaches become part of the coach and are more specifically covered by Heading 8607. The Board's Circular No. 31/93 dated 22-11-1993 and the cited Tribunal decisions supported this classification.

Conclusion: The goods were correctly classifiable under Heading 8607 and not Heading 7611, and the Revenue's challenge failed.

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