Machine-specific filter cartridges classifiable as parts of purifying machinery, not by constituent material, under the applicable heading.

Specially designed filter element cartridges used only in powershift transmission systems are treated as machine parts rather than as glass fibre articles. Applying Section XVI Notes 2(a) and 2(b), goods used solely or principally with a particular machine are classified as parts under the heading applicable to that machine. The constituent-material approach was rejected because the cartridges had a distinct part number, performed a specific filtering function, and had assumed the character of a part of purifying machinery. The cartridges were therefore classifiable under sub-heading 8421.99 and not under sub-heading 7019.39, with the Revenue's classification set aside.

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Issues: Whether the imported filter element cartridges were classifiable as parts of purifying machinery under sub-heading 8421.99 or as glass fibre articles under sub-heading 7019.39.

Analysis: The item was found to be specially designed and manufactured for use only as a filtering element in powershift transmission systems, had a specific part number, and performed a distinct function as part of the filtering apparatus. On that basis, it was held to have assumed the character of a part rather than retaining the identity of glass fibre per se. Applying Note 2(a) and (b) of Section XVI, goods used solely or principally with a particular machine are to be classified as parts under the heading applicable to that machine. The reliance on the HSN explanatory notes for classifying the item by constituent material was rejected because the cited examples did not cover a machine part of this nature. Support was also drawn from prior Tribunal decisions treating filtering elements as parts.

Conclusion: The filter element cartridges were correctly classifiable as parts of purifying machinery under sub-heading 8421.99 and not under sub-heading 7019.39. The classification adopted by the Revenue was set aside.

Ratio Decidendi: A specially designed and solely machine-specific component used as a filtering element must be classified as a part of the machine under the heading applicable to that machine, and not by its constituent material.

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