Classification of special-purpose thread roll dies as machine parts, not interchangeable tools, under the tariff headings.

Thread roll dies specially made for use in a thread rolling machine were classified as machine parts suitable for use solely or principally with such machines, not as interchangeable hand tools. The earlier High Court ruling on similar goods was treated as relevant because it distinguished component parts of machinery from tools, and Heading 84.45/48 was read as the appropriate analogue for such machine parts. Heading 82.05 was confined to interchangeable tools of a different character. The goods were therefore classifiable under Heading 84.45/48 and not under Heading 82.05, with relief granted to the assessee.

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Issues: Classification of thread roll dies whether under Heading No. 82.05 as interchangeable hand tools or under Heading No. 84.45/48 as machine tools or parts suitable for use solely or principally with such machine tools.

Analysis: The goods were specially made thread roll dies for use in a thread rolling machine. The earlier High Court decision, though rendered under the Indian Tariff Act, 1934, was treated as relevant because it classified similar goods as component parts of machinery rather than as tools and parts thereof. Heading No. 84.45/48 was regarded as analogous to the earlier tariff entry dealing with component parts of machinery, whereas Heading No. 82.05 covered interchangeable tools of a different character.

Conclusion: The goods were held classifiable under Heading No. 84.45/48 and not under Heading No. 82.05, in favour of the assessee.

Final Conclusion: The appeal was allowed and consequential relief was directed on the basis that the disputed goods were not interchangeable tools but parts suitable for use with the machine.

Ratio Decidendi: Goods specially designed for exclusive or principal use with a machine are classifiable as machine parts or accessories rather than as interchangeable tools when the tariff structure draws that distinction.

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