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Issues: Whether special projection bulbs imported for a grinding machine were classifiable as electric lighting bulbs under Item 60(2) of the Indian Customs Tariff or as component parts of machinery under Item 72(3).
Analysis: The bulbs were found to be specially shaped and specially manufactured for the projection unit built into the grinding machine. The projection arrangement was an inbuilt mechanism essential to the effective working of the machine, because it enabled inspection of the tools produced and could not be treated as a mere lighting facility. Since the bulbs were indispensable to that machinery and had special characteristics not required for ordinary illumination, the departmental view was held to be unreasonable.
Conclusion: The bulbs fell under Item 72(3) as component parts of machinery and not under Item 60(2) as electric lighting bulbs.
Final Conclusion: The departmental classification was set aside and the appeal challenging the assessee's classification succeeded in the assessee's favour.
Ratio Decidendi: Goods specially designed and indispensable for an inbuilt functional mechanism of machinery are classifiable as component parts of that machinery when they have special shape or quality and are not intended for ordinary use.