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AI Drafter - (New and Powerful) ✕ Generate professional replies, appeals, opinions to Show Cause Notices, assessment orders, audit objections, and other legal communications using TaxTMI's AI Drafter.
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Issues: Whether the imported DLN Coater - R-100 was classifiable under Heading 84.19 as machinery for treatment of materials by a process involving change of temperature, or under the residuary Heading 84.79 as machinery having individual functions not specified elsewhere.
Analysis: The machine was described as coating equipment for deposition of thin films and the material coated was not itself subjected to treatment by a process involving a change of temperature. The heating took place in the coater to convert the precursor into plasma for deposition, and that temperature change was only incidental to the coating function. Chapter Note 2(e) did not assist the importer because the machine did not answer to Heading 84.19 in preference to the residuary heading. The HSN notes also supported classification of coating machinery under Heading 84.79 where heating was merely ancillary to the main mechanical function.
Conclusion: The machine was not classifiable under Heading 84.19 and was correctly classifiable under Heading 84.79 / sub-heading 8479.89. The classification adopted by the revenue authorities was upheld.
Final Conclusion: The appeal failed and the classification of the imported machine under the residuary customs heading was sustained.
Ratio Decidendi: Where heating occurs only within the machine to facilitate deposition or coating and the material itself is not subjected to a temperature-changing treatment, classification lies under the residuary heading rather than the heading for treatment of materials by change of temperature.
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