Complete testing setups classified as test benches, with exemption for measuring instruments denied because devices were component parts.

Imported calibration and testing equipment was held to be a complete testing setup, not standalone measuring instruments, because the literature showed multiple units working together and the measuring devices formed only component parts. On that basis, the goods were classified according to their essential character as test benches under Heading 9031.20, and Heading 9026.80 did not apply. Because the notification extended relief only to measuring instruments and instruments used for measuring and checking, the exemption under Notification No. 118/86-Cus. was unavailable. The customs classification was upheld and the appeal failed.

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Issues: (i) Whether the imported calibration and testing equipment were classifiable under Heading 9031.20 as test benches or under Heading 9026.80 as measuring/checking instruments; (ii) Whether the goods were entitled to the benefit of Notification No. 118/86-Cus.

Issue (i): Whether the imported calibration and testing equipment were classifiable under Heading 9031.20 as test benches or under Heading 9026.80 as measuring/checking instruments.

Analysis: The equipment literature showed that each imported set consisted of multiple units and that the measuring devices such as rotameters, manometers, milliampere meters and electronic leak test devices formed only parts of a larger apparatus. The decisive consideration was that the imported consignments were complete testing setups, not standalone measuring instruments. On that basis, their essential character was that of test benches, and Heading 9026.80 was not attracted.

Conclusion: The goods were correctly classified under Heading 9031.20, not under Heading 9026.80.

Issue (ii): Whether the goods were entitled to the benefit of Notification No. 118/86-Cus.

Analysis: The notification extended relief to measuring instruments and instruments used both for measuring and checking. Since the imported articles were complete test benches in which measuring or checking instruments were only constituent parts, they did not answer the description of eligible goods under the notification.

Conclusion: The benefit of Notification No. 118/86-Cus. was not available.

Final Conclusion: The classification adopted by the customs authorities was upheld and the exemption claim failed, resulting in dismissal of the appeal.

Ratio Decidendi: Where imported equipment is a complete testing setup whose measuring devices are merely component parts, it is classified according to its essential character as a test bench and not as a measuring instrument, and an exemption limited to measuring instruments does not apply.

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