Classification of imported filter screen upheld as a machine part, preserving notification benefit despite Revenue's HSN-based challenge.

Imported stainless steel wedger filter screen was examined for classification under Heading 8421.99 as a filter element or under Heading 7326.99 as an article of stainless steel, and for eligibility to Notification No. 172/89. The operative distinction turned on the true nature of the goods: the appellate authority found that the item was not a filter element, but only a part wholly and solely designed for use in filtering machinery. In the absence of catalogue or other material establishing the exact function and identity of the goods, that finding was accepted. The HSN note relied on by the Revenue, being applicable to filter elements, was held not decisive on those facts, and the respondent's classification and notification benefit were sustained.

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Issues: Whether the imported stainless steel wedger filter screen was classifiable as a filter element under Heading 8421.99 or as an article of stainless steel under Heading 7326.99, and whether the benefit of Notification No. 172/89 was available.

Analysis: The dispute turned on the true nature of the imported goods. The Revenue relied on the HSN notes to contend that the screen functioned as a filtering element and should therefore be classified by its constituent material. The appellate authority had recorded a categorical finding that the item was not a filter element, but only a part wholly and solely designed for use in filtering machinery. In the absence of the catalogue or other material showing the exact function and identity of the goods, that finding was accepted. Since the HSN note cited by the Revenue applied to filter elements, it was not decisive on the facts found by the appellate authority.

Conclusion: The item was not to be classified as a filter element under Heading 8421.99 and the Revenue's appeal failed. The classification in favour of the respondent was sustained, with the notification benefit remaining available on that footing.

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