End-use based tariff classification prevails where radiator cores serve different machinery and motor vehicle applications.

Distinct tariff entries for machinery parts and motor vehicle parts required classification of radiator cores according to their admitted end use. Where certain cores were used in heavy machinery and others in motor vehicles, and the goods were not shown to be interchangeable across those uses, there was no basis to club all radiator cores under Heading 87.08 to deny the larger exemption limit. The assessee's separate classification was upheld, and the Revenue's attempt to impose a uniform heading was rejected.

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Issues: Whether radiator cores of different sizes and designs were correctly classifiable under different tariff headings on the basis of end use, and whether all such goods could be brought under Heading 87.08 for denying the larger exemption limit.

Analysis: The tariff contains separate entries for parts of machinery and parts of motor vehicles. The Department did not dispute that radiator cores of certain sizes and specifications were used in heavy machinery, while radiator cores of different sizes and designs were used in motor vehicles. Since the classification claimed by the assessee was founded on admitted end use, and the goods were not shown to be interchangeable across the two uses, there was no basis to club all radiator cores under Heading 87.08.

Conclusion: The classification adopted by the assessee was upheld and the Revenue's claim for uniform classification under Heading 87.08 was rejected.

Final Conclusion: The appellate order sustaining separate classification of radiator cores according to their end use was affirmed, and the Revenue's appeal failed.

Ratio Decidendi: Where tariff entries are distinct and the end use of the goods is admitted to differ, classification must follow the relevant end use rather than a uniform heading based only on one principal use.

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