Tariff classification of mill rolls: complete rolls remain within the specific heading covering rolls therefor, not the residual parts entry.

Rolls for metal re-rolling mills were held to fall within the heading that expressly covers both metal re-rolling mills and rolls therefor, and not to be shifted to the residual parts entry merely because they are also described as parts of rolling mills. The interpretation that the heading could be confined to rolling mills alone and exclude rolls was found impermissible, as it conflicted with the wording of the tariff heading. Although the drafting created some overlap, the HSN Explanatory Notes showed a different treatment of rolls and other parts, supporting the view that complete rolls are classifiable under sub-heading 8455.10.

---

---

Issues: Whether rolls for metal re-rolling mills are classifiable under sub-heading 8455.10 as all goods other than parts, or under sub-heading 8455.90 as parts.

Analysis: The heading itself covers both metal re-rolling mills and rolls therefor. A complete roll for a metal rolling mill is not to be treated as a part of the main heading for the purpose of classification under the residual parts entry. The Commissioner (Appeals)' view that rolls are not part of rolling mills was rejected as contrary to the wording of the heading. At the same time, the apparent overlap arose because of imperfect drafting, and the HSN Explanatory Notes showed a different structural treatment of rolls and other parts. An interpretation that would confine the heading to rolling mills alone and exclude rolls was held to be impermissible.

Conclusion: Rolls for metal rolling mills are not excluded from sub-heading 8455.10 merely because they are also described as parts of rolling mills, and the classification adopted by the appellate authority was not interfered with.

---