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Issues: Whether metal rolls are classifiable under sub-heading 8455.10 as goods other than parts, or under sub-heading 8455.90 as parts, in Heading 84.55 of the Central Excise Tariff Act, 1985.
Analysis: The wording of Heading 84.55 treats "metal-rolling mills and rolls therefor" as the goods covered by the heading, and the tariff structure shows only two sub-classifications, namely 8455.10 for all goods other than parts and 8455.90 for parts. The General Explanatory Notes to the Schedule make it clear that a single dash denotes sub-classification of the heading itself, so the expression "parts" in 8455.90 covers parts of the goods in the heading, but does not convert "rolls" into parts merely because they may serve rolling mills. The reliance on the Harmonised System of Nomenclature was held to be inappropriate because the Central Excise Tariff adopted a different and more limited sub-classification scheme for this heading.
Conclusion: Metal rolls are classifiable under sub-heading 8455.10 and not under sub-heading 8455.90; the assessee succeeds on classification.