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Issues: (i) Whether epoxy insulated stator coils and accessories imported for hydro electric generators were classifiable under heading 8503 as parts of generators or under heading 8544 as insulated wires and cables.
Analysis: The goods were shown by the invoice, catalogue and supplier's certificate to be specially made for the Sharavathy hydro electric generating units and usable only with those generators. The governing rule was Note 2(b) of Section XVI, under which parts suitable for use solely or principally with a particular kind of machine are to be classified with that machine. On that basis, the goods were not treated as general insulating materials but as generator-specific stator coils. The material relied on supported classification under heading 8503, while heading 8544 was found inapplicable.
Conclusion: The goods were classifiable under heading 8503 and not under heading 8544, and the classification adopted by the Revenue was rejected.
Final Conclusion: The appeal succeeded, the impugned order was set aside, and the assessee obtained the classification relief claimed.
Ratio Decidendi: Parts proved by design, description and supplier certification to be solely or principally intended for a specific machine are to be classified with that machine under Note 2(b) of Section XVI rather than under a more general tariff heading.