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Issues: Whether disposable syringes and hypodermic needles, when cleared separately, were entitled to the concessional rate of duty under the relevant notification, or were to be denied the benefit as mere parts of a medical appliance.
Analysis: The goods were specifically classified under heading 9018, with separate coverage for syringes and hollow needles under the relevant sub-headings. The mere fact that the items function in conjunction with each other did not make them parts or accessories of another medical appliance. The classification scheme itself treated syringes and needles as identifiable instruments used in medical science, and there was no separate classification for their parts and accessories in the chapter. On the material examined, the concession could not be denied on the theory that the goods were incapable of independent use.
Conclusion: The concessional rate of duty was correctly available to the respondent, and the Revenue's challenge failed.