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Issues: Whether polypropylene liner fabric imported for use in tyre manufacturing machinery was classifiable as a component part of machinery under Item 72(3) of the Indian Customs Tariff, or as textile manufactures under Item 53.
Analysis: Item 72(3) covered only those parts that were essential for the working of the machine or apparatus and were given a special shape or quality not essential for any other purpose. The imported liner fabric was used to protect tyre fabric from moisture and dust during manufacture, but it was not a constituent of the machine itself. It came in running lengths of different sizes and widths, was capable of use in similar industrial processes, and was therefore not confined to any particular machine or its assembly. The material was in the nature of an accessory rather than a machine component.
Conclusion: The imported liner fabric was not classifiable as a component part of machinery under Item 72(3) and was correctly classified under Item 53. The conclusion was against the assessee.
Ratio Decidendi: For tariff classification as a machine component, the imported article must be an essential part of the machine itself and must possess a special shape or quality making it unsuitable for other uses; an article functioning merely as an accessory or protective aid is not a component part.
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