Classification of steel castings after basic finishing: goods remained castings, not identifiable machinery parts.

Steel castings cleared after annealing, short blasting and chipping remained classifiable as castings under Chapter 73 because the evidence did not show any further process beyond basic finishing and removal of surface defects. Applying the settled principle that a cast article is complete once proof machined and surface defects are removed, the goods were not shown to be identifiable machinery parts under Chapter 84. The classification under Chapter 73 was therefore sustained and the contrary Revenue contention was rejected.

---

---

Issues: Whether steel castings cleared after annealing, short blasting and chipping were classifiable under Chapter 73 or as identifiable machinery parts under Chapter 84.

Analysis: The impugned order found that the respondents were clearing castings after annealing, short blasting and chipping, and relied on the settled position that a cast article is complete when it has been proof machined and surface defects have been removed. No evidence was produced to show that any further process was undertaken beyond those noted by the appellate authority. On that basis, the finding that the goods remained castings and were not shown to be identifiable machinery parts was upheld.

Conclusion: The classification under Chapter 73 was sustained and the Revenue's plea for classification under Chapter 84 was rejected.

Final Conclusion: The order rejecting the Revenue's classification challenge was upheld, and the appeal failed.

Ratio Decidendi: Where the evidence does not show that castings have undergone any process beyond basic finishing and surface-defect removal, they remain classifiable as castings and not as identifiable machinery parts.

---