Machine parts classification upheld for specially designed printed circuit boards; new tariff heading claim rejected at appeal.

Printed circuit boards specially designed for use in a specific CNC system, populated with components and identifiable by part number, were treated as parts of the machine rather than as separate goods, consistent with the tariff and HSN notes. The attempt by Revenue to press a different tariff heading at the appellate stage was found impermissible in the circumstances, so the original classification was sustained and the alternative classification rejected.

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Issues: Whether printed circuit boards designed for use in a specific CNC system and identifiable by part number were classifiable as parts of the machine, and whether the Revenue could seek a different tariff heading at the appellate stage.

Analysis: The item was found to be specially designed to function as part of the machine, populated with components, and identifiable as a specific machine part. The classification was supported by the tariff and HSN notes, as well as the Collectors' Conference view treating such printed circuit boards as parts of the forge press. The attempt by the Revenue to press a new classification not adopted in the original proceedings was also found impermissible in the circumstances.

Conclusion: The printed circuit boards were correctly treated as parts of the machine and the Revenue's request for a different classification was rejected.

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