Integrated automatic spraying line classified as a single apparatus, with notification benefit sustained for the composite equipment.

A fully automatic spraying machine used for painting leather, together with conveyors, dryers and coolers forming an integrated line, was treated as a single composite apparatus for classification under Heading 8424. The description of the goods, supporting literature and past practice showed that the constituent units were not separate machines but integral parts of the spraying line. On that basis, the benefit of Notification No. 43/78-Cus. was sustained and the Revenue's challenge failed.

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Issues: Whether the automatic spraying machine, along with conveyors, dryers and coolers, was correctly classified under Heading 8424 and entitled to the benefit of Notification No. 43/78-Cus.

Analysis: The machine was found to be a fully automatic, single integral line for painting leather, with conveyors, dryers and coolers forming an integrated part of the spraying line rather than separate machines. The description of the goods and the literature supported this view, and the past practice of extending the notification benefit to similar goods was also noted. On that basis, there was no basis to treat the components separately or to deny the notification benefit.

Conclusion: The classification under Heading 8424 and the availability of Notification No. 43/78-Cus. were upheld, against the Revenue.

Final Conclusion: The Revenue challenge failed, and the assessee's classification and notification benefit were sustained.

Ratio Decidendi: Where imported equipment is a single integrated automatic line, its constituent conveyors, dryers and coolers may be treated as part of the whole for classification and allied exemption purposes, rather than as separately classifiable machines.

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