Tariff classification turns on actual commercial function, and an unrelated certificate cannot change the heading for oil-seed crushing machinery.

Tariff classification of palm oil mill machinery depended on its actual commercial function as equipment for crushing oil seeds, not on an administrative certificate. The Tribunal applied its earlier view that an oil expeller is not machinery used in the milling industry and rejected the contention that the goods had multiple functions, because no material showed uses beyond oil-seed crushing. The Assistant Director of Horticulture's certificate was held irrelevant to classification. On that basis, the goods were not classifiable under Heading 8437.00 and were correctly classified under Heading 8479.19, leaving the departmental classification undisturbed.

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Issues: Whether the goods described as palm oil mill machinery were classifiable under Heading 8437.00 or under Heading 8479.19 of the Central Excise Tariff Act, 1985.

Analysis: The machinery was found to be used for working and crushing oil seeds, and the Tribunal's earlier view that an oil expeller is not a machine used in the milling industry was applied. The certificate issued by the Assistant Director of Horticulture was held to be irrelevant to tariff classification. The plea that the machinery had multiple functions was rejected for want of any material showing uses other than crushing of oil seeds.

Conclusion: The goods were not classifiable under Heading 8437.00 and were correctly classifiable under Heading 8479.19, so the appeal failed.

Final Conclusion: The classification adopted by the department was upheld and the assessee obtained no relief.

Ratio Decidendi: Goods are to be classified under the tariff heading corresponding to their actual commercial function, and an unrelated administrative certificate cannot alter that classification.

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