Principal function test governed classification of composite pump sets, securing tariff exemption for power driven pumps.

Composite power driven pump sets were classified as power driven pumps under Chapter heading 84.13 because the principal function of the set was pumping, and classification followed the component performing that principal function. The CBEC clarification was treated as binding on the Department, so the view that the coupling was merely a motor component was not accepted. On that basis, the pump sets qualified for exemption under Notification No. 64/86, and the demand did not survive.

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Issues: Whether Love-Joy Coupling used in power driven pump sets is classifiable as part of power driven pumps under Chapter heading 84.13 and whether the appellant is entitled to exemption under Notification No. 64/86.

Analysis: The deciding factor was the CBEC clarification that the principal function of a pump set is that of the pump and that composite machines are to be classified by reference to the component performing the principal function. On that basis, the pump set was treated as falling under Chapter heading 84.13. The Department was bound by the Board's clarification, and the contrary view that the coupling was only a motor component was not accepted.

Conclusion: The power driven pump sets manufactured by the appellant were held classifiable under Chapter heading 84.13 and entitled to the benefit of Notification No. 64/86.

Final Conclusion: The demand did not survive, and the appellant obtained the consequential relief flowing from the classification and exemption.

Ratio Decidendi: Where a composite pump set performs the principal function of pumping, it is to be classified as a pump under the relevant tariff heading and the exemption available to power driven pumps applies accordingly.

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