Composite goods classification under Customs Tariff turns on independent functions and interpretative rules, not forced accessory treatment.

Classification of composite imported goods under Chapter 90 must follow the tariff heading and the General Interpretative Rules. A microscope and micromanipulator used together for in vitro fertilisation were treated as two functional components, each necessary for the intended use, and the micromanipulator could not be treated as merely an accessory of the microscope. As no separate basis was established to classify the goods as microscope parts, accessories, or under the rival heading, the declared classification was upheld and heading 90118000 was rejected.

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Issues: Whether the imported goods, consisting of a microscope and micromanipulator used together for in vitro fertilisation, were classifiable under heading 90118000 as microscopes or under the declared heading 90189099 of the Customs Tariff.

Analysis: The dispute was confined to classification under Chapter 90 of the First Schedule to the Customs Tariff Act, 1975 and had to be resolved by applying the tariff heading and the General Interpretative Rules. The goods were found to comprise two functional components, both necessary for the intended medical use, and neither component could be treated as merely ancillary to the other. The micromanipulator was not an accessory of the microscope, and the customs authorities had not established a separate basis for treating the goods as microscope parts or accessories or for segregating them for independent assessment. In the absence of a sustainable case for classification under the rival heading, the declared classification could not be displaced.

Conclusion: The classification under heading 90118000 was rejected and the declared classification was accepted in favour of the assessee.

Ratio Decidendi: Classification of composite imported goods must be determined by the applicable tariff heading and interpretative rules, and an article cannot be forced into an accessory or residual entry where its components perform independent essential functions and no separate classification basis is established.

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