Parts or accessories classification follows exclusive use with the principal machine; duty demand was remanded for fresh quantification.

Goods specially designed to work only in tandem with a principal machine and having no independent function were treated as parts or accessories of that machine under the tariff note, so the capsule filling machine, capsule loading machine and related attachments were classified under Heading 8422.90 rather than the alternative headings claimed by the assessee. The duty computation was found to require fresh working by the proper officer after hearing the assessee, and the demand was directed to be altered if necessary on re-quantification. The appeals therefore succeeded only to the limited extent of remand for fresh quantification.

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Issues: (i) Whether the capsule filling machine, capsule loading machine, and related attachments were classifiable under Heading 8422.90 as parts or accessories of capsule filling machinery, or under Headings 8479.00 or 8428.00 as claimed by the assessee; (ii) whether the duty demand required re-quantification on remand.

Issue (i): Whether the capsule filling machine, capsule loading machine, and related attachments were classifiable under Heading 8422.90 as parts or accessories of capsule filling machinery, or under Headings 8479.00 or 8428.00 as claimed by the assessee.

Analysis: The disputed capsule loading machine was found to operate in tandem with the capsule filling machine and to be specially designed for ancillary use in that machinery. The attachments and accessories in the connected appeals were also found to have no independent function or use apart from serving the capsule filling machine. On that basis, and applying Note 2(b) to Section XV, the goods were treated as component parts or accessories of the capsule filling machine rather than independent machines falling under the alternative headings claimed by the assessee.

Conclusion: The classification under Heading 8422.90 was upheld against the assessee.

Issue (ii): Whether the duty demand required re-quantification on remand.

Analysis: The calculations of duty were found to require re-working by the proper officer after hearing the assessee, and the demand was directed to be altered if necessary after such re-quantification.

Conclusion: The matter was remitted for re-quantification of the duty demand.

Final Conclusion: The appeals succeeded only to the limited extent of remand for fresh quantification, while the disputed goods were held classifiable under Heading 8422.90 as parts or accessories of capsule filling machinery.

Ratio Decidendi: Goods specially designed to function only in tandem with a principal machine, and having no independent function, are classifiable as parts or accessories of that machine under the relevant tariff note.

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