Integral furnace components must be classified with the main equipment when dedicated control panels are essential to its operation.

Control panels and power supply units specifically designed for and dedicated to a furnace were treated as integral parts of the furnace when they were used with it and the furnace could not function effectively without them. Applying Section Note 2(b) of Section XVI, the Tribunal accepted that a part cleared with the main equipment and serving its operation is classifiable with that equipment rather than as a separate item. The control panels were therefore classified with the furnace under Chapter Heading 85.14 and not independently under Chapter Heading 85.37, and the Revenue's appeal failed.

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Issues: Whether the control panels or power supply units designed for and used with the furnace were classifiable independently under Chapter Heading 85.37 or, as an integral part of the furnace, along with Chapter Heading 85.14 by applying Section Note 2(b) of Section XVI.

Analysis: The control panels were found to be specifically designed and dedicated to the furnace, intended to control and distribute electricity to it through inter-connection of cables and hoses. The Tribunal accepted the earlier view that where a part is utilised with the main equipment and cleared along with it, and where the equipment cannot function effectively without such part, the part is to be classified with the main equipment. On that reasoning, the power supply unit or control panel was treated as an integral component of the furnace and not as an independent item.

Conclusion: The control panels were classifiable along with the furnace under Chapter Heading 85.14 and not separately under Chapter Heading 85.37; the Revenue's appeal failed.

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