Tariff classification of railway-specification generator and transformer parts follows specific machine headings, not locomotive parts heading.

Parts of generators and transformers made to railway specifications remained classifiable under the tariff headings for parts of electric motors, generators and transformers, because the tariff description and Section XVI notes controlled the classification. Their use in railway locomotives did not change their essential character or shift them to the more general heading for parts of railway locomotives. Earlier classification practice was not controlling under the applicable tariff structure. The resulting classification under Headings 85.03 and 85.04 was upheld, and Heading 86.03 was rejected.

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Issues: Whether parts of generator and transformer manufactured to Railway specifications and used in railway locomotives were classifiable under Heading 86.03 as parts of railway locomotives, or under Headings 85.03 and 85.04 as parts of electric motors, generators and transformers.

Analysis: Heading 85.03 covers parts suitable for use solely or principally with the machines of Heading 85.01 or 85.02, and Heading 85.01 includes electric motors and generators. The goods in question were admitted to be parts of electric motors and generators, and Heading 85.03 specifically covers such parts. Note 2 of Section XVI supported classification by the tariff description. The fact that the goods were manufactured to Railway specifications and used in locomotives did not alter their essential character as parts of electric motors, generators and transformers. The earlier classification authorities were also not controlling in view of the present tariff structure.

Conclusion: The goods were correctly classifiable under Headings 85.03 and 85.04, and not under Heading 86.03.

Final Conclusion: The appeal failed and the tariff classification adopted by the Revenue was sustained.

Ratio Decidendi: Where tariff headings specifically cover parts of particular machines, classification must follow the specific tariff description and section notes, and use in railway equipment or manufacture to railway specifications does not shift the goods to a more general locomotive-parts heading.

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