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Classification of imported goods under Heading 84.07 or Heading 87.04/06(1) Detailed Analysis: The case involves an appeal against the order of the Collector (Appeals) regarding the classification of certain imported components/sub-assemblies of hydrostatic steering systems. The appellants, who are manufacturers of Hydraulic Systems, imported these components and claimed that they should be classified under Heading 84.07 as hydraulic engines and motors. However, the A.C. classified them under Heading 87.04/87.06 as parts and accessories of motor vehicles. The appellants argued that the components were designed for heavy earth-moving machinery and stationary equipment, not fast-moving vehicles, and should be classified based on their function. They provided technical notes on the system's design and operation, emphasizing the transformation of fluid energy into motive power for steering. The A.C. and the Collector (Appeals) relied on the application list of the manufacturer, M/s. Danfoss, which showed a wide range of uses in vehicles and machinery, supporting the classification under Heading 87.04/06(1) for motor vehicle parts. The A.C. rejected the appellant's claim that the components should be classified under Heading 84.07 as hydraulic engines, emphasizing that they were part of control equipment like steering systems used in motor vehicles. The A.C. noted that the components included distributor valves and rotary meters in addition to hydraulic cylinders, making them unsuitable for classification solely under Heading 84.07. The A.C. and the Collector (Appeals) found that the components were integral to steering systems in various motor vehicles, as evidenced by the manufacturer's application list, justifying their classification under Heading 87.04/06(1) for parts and accessories of motor vehicles. The Tribunal considered the submissions and technical details provided by the appellants but focused on the essential criterion for classification under Heading 84.07, which covers hydraulic engines and motors. The Tribunal agreed with the A.C. and the Collector (Appeals) that the components, although functioning based on hydraulic principles, were more appropriately classified under Heading 87.04/06(1) due to their specific application in motor vehicles and machinery. The Tribunal upheld the order and rejected the appeal, concluding that the components were rightly classified as part of motor vehicles under Heading 87.04/06(1) based on their function and intended use in steering systems for various vehicles and equipment.
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