Seat adjusters are accessories, not essential seat parts, where the seat remains functional without them.

Goods used to improve seat adjustment, comfort and convenience were treated as accessories rather than essential parts where the seat remained complete and functional without them. Applying the distinction between a part and an accessory, the analysis notes that Chapter 9401 covers seats and their parts, while Chapter 8708 is broad enough to include motor vehicle parts and accessories. Because the rail assembly front seat adjuster, seat slider assembly and rear back lock assembly were fitted to the vehicle floor and did not form indispensable components of the seat, their character was not altered by supply through seat manufacturers. They were classified under Chapter 8708, not as seat parts under Chapter 9401.

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Issues: Whether the goods manufactured by the assessee, namely rail assembly front seat adjuster, assembly slider seat and rear back lock assembly, were classifiable as parts of seats under Chapter 9401 of the Central Excise Tariff Act, 1985 or as parts and accessories of motor vehicles under Chapter 8708 of the Central Excise Tariff Act, 1985.

Analysis: Chapter 9401 covers seats and their parts, while Chapter 8708 is wide enough to cover parts and accessories of motor vehicles. The goods in question were used to improve adjustment, comfort and convenience of the seat, but the seat remained complete and functional without them. They were fitted on the floor of the vehicle and did not form essential components of the seat. Mere supply of the goods through seat manufacturers did not alter their character. The distinction between a part and an accessory was applied to hold that an accessory is supplementary and not indispensable to the functioning of the principal item.

Conclusion: The goods were not parts of seats under Chapter 9401; they were accessories of motor vehicles under Chapter 8708. The appeal of the Revenue failed and the classification claimed by the assessee was accepted.

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