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Issues: Whether the imported special purpose machine for plugging carburettor bodies was classifiable under Tariff Heading 84.59(1), Tariff Heading 84.59(2), or Tariff Heading 84.45/48 of the Customs Tariff Act, 1975.
Analysis: The machine's main function was to plug the holes in carburettor bodies, while trimming of excess lead, leakage checking, and numbering were incidental to that principal operation. Applying Section Note 3 of Section XVI and Chapter Note 5 of Chapter 84 of the First Schedule to the Customs Tariff Act, 1975, classification had to follow the principal function of the composite machine. The plugging operation did not amount to working metal in the sense required for machine tools, did not change the shape or form of the metal, and did not fall within Tariff Heading 84.45/48. The machine also did not answer the description of treating metal so as to fall under Tariff Heading 84.59(2). Since it was not covered by any other heading in Chapter 84, the proper classification was under the residuary Tariff Heading 84.59(1).
Conclusion: The machine was correctly classifiable under Tariff Heading 84.59(1), and the alternative classifications were rejected.
Final Conclusion: The appeal succeeded, the appellate order was set aside, and the original classification in favour of the Revenue was restored.
Ratio Decidendi: For classification of a composite machine, the principal function determines the tariff heading, and incidental operations do not alter classification where the machine does not fall within a specific competing heading.