Direct nexus test for machine parts under tariff classification controls whether fuel injection pipes fall within the engine heading.

For tariff classification of machine parts under Chapters 84 and 85, the decisive test is whether the part has a direct nexus with the machine for which it is claimed, and not merely an indirect connection through an intermediate machine. Fuel injection pipes used directly as parts of a diesel engine were therefore treated as parts of Heading 84.08/84.09, even though that engine was installed in an electric generating set. A remote relationship with the generating set was insufficient to shift classification to the heading for generating-set parts. The classification accordingly favoured the Revenue and the departmental view was sustained.

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Issues: Whether the imported high pressure pipes were classifiable under Heading 85.03 as parts of an electric generating set, or under Heading 84.09 as parts of a diesel engine.

Analysis: The imported pipes were found to be fuel injection pipes used directly as parts of a diesel engine falling under Heading 84.08. Heading 84.09 covers parts suitable for use solely or principally with engines of Heading 84.07 or 84.08. The fact that the diesel engine was itself used in an electric generating set classifiable under Heading 85.02 did not create a direct nexus between the pipes and the generating set. For classification of parts of machines falling under Chapters 84 or 85, the relevant test was whether there was a direct nexus between the part and the machine, without involvement of an intermediate machine.

Conclusion: The imported pipes were correctly classifiable under Heading 84.09 and not under Heading 85.03, and the classification was in favour of the Revenue.

Final Conclusion: The appeal failed, and the departmental classification was sustained.

Ratio Decidendi: For tariff classification of parts of machines under Chapters 84 or 85, the part must have a direct nexus with the machine claimed, and classification cannot be based on a remote or intermediate use through another machine.

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