Tariff classification of powder conveying equipment confirmed under handling machinery heading, not as a dairy machinery part.

A powder conveying system used in dairy machinery was classified under Heading 84.28 as machinery for mechanical handling of materials, not under Heading 84.34 as a part of dairy machinery. The product's function of conveying milk powder brought it within the scope of conveying and handling equipment covered by Heading 84.28, and the Explanatory Notes confirmed that specialised handling machinery remains classifiable there even when designed for a specific industry. Because it was specifically covered by Heading 84.28, it could not be treated as a mere component under a different heading. The revenue's classification was upheld.

---

---

Issues: Whether a powder conveying system manufactured for use in dairy machinery was classifiable under Heading 84.34 as parts of dairy machinery or under Heading 84.28 as other lifting, handling, loading or unloading machinery.

Analysis: The product admittedly conveyed milk powder and therefore answered the description of machinery for mechanical handling of materials. The Explanatory Notes to Heading 84.28 cover a wide range of handling machinery, including conveying equipment, and state that such goods remain classifiable there even if specialised for a particular industry. Under Note 2(a) to Section XVI, goods included in any heading of Chapters 84 and 85 are to be classified in their respective headings. Since the impugned product was specifically covered by Heading 84.28, it could not be treated as a mere part of dairy machinery under Heading 84.34.

Conclusion: The product was correctly classifiable under Heading 84.28 and not under Heading 84.34; the classification adopted by the revenue was upheld.

Final Conclusion: The appeal failed and the classification of the powder conveying system under Heading 84.28 stood confirmed.

Ratio Decidendi: A machine or system specifically falling within a tariff heading for handling or conveying goods must be classified in that heading even if it is intended for incorporation in another industry-specific machine, and it cannot be treated as a mere part under a different heading.

---