Composite machine classification and territorial jurisdiction objections failed; integrated equipment was classified by function under the tariff.

Appellate jurisdiction was upheld where the Revenue itself had filed the appeal before the Commissioner (Appeals) without objecting to territorial competence, and the governing rule for the relevant period vested jurisdiction in Vadodara; an office order could not displace that rule without amendment. The goods were also held correctly classifiable under Heading 8430.00 because the deck assembly was a complete integrated machine or equipment performing a single defined function for mineral oil and natural gas extraction; under Note 4 of Section XVI, such composite equipment is classified by its function and not as mere parts under Heading 8431.00. Both Revenue objections failed.

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Issues: (i) whether the Commissioner (Appeals), Vadodara lacked jurisdiction to entertain the Revenue's appeal; and (ii) whether the goods cleared by the assessee were classifiable under Heading 8430.00 or as parts under Heading 8431.00.

Issue (i): whether the Commissioner (Appeals), Vadodara lacked jurisdiction to entertain the Revenue's appeal.

Analysis: The Revenue had itself filed the appeal before the Commissioner (Appeals) without raising any objection to territorial jurisdiction. The applicable rule for the relevant period conferred jurisdiction on the Vadodara Commissioner (Appeals), and an office order reallocating jurisdiction could not override the rule in the absence of amendment.

Conclusion: The jurisdictional objection failed and the Commissioner (Appeals), Vadodara had jurisdiction.

Issue (ii): whether the goods cleared by the assessee were classifiable under Heading 8430.00 or as parts under Heading 8431.00.

Analysis: The goods were a complete deck assembly with facilities, including module and helideck, intended for extraction of mineral oil and natural gas. On the records and literature, the item was a complete machine or equipment contributing together to a clearly defined function. Under Note 4 of Section XVI of the Central Excise Tariff Act, 1985, such a composite machine falls in the heading appropriate to its function, and not as mere parts.

Conclusion: The goods were correctly classifiable under Heading 8430.00 and not under Heading 8431.00.

Final Conclusion: Both objections raised by the Revenue were rejected, and the classification adopted by the lower appellate authority was upheld.

Ratio Decidendi: A composite machine or integrated equipment consisting of individual components intended to perform a single defined function is to be classified under the heading appropriate to that function, and a party that invokes appellate jurisdiction without objection cannot later challenge it when the governing rule confers that jurisdiction.

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