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Issues: Whether the imported items, though stated to be required for the operation of the machine, could be treated as component parts classifiable under the main tariff heading instead of as separately invoiced accessories or spare parts.
Analysis: The items were found to be essential for working of the machine, but it was not established that they were component parts of the main machine. The invoice described them as accessories and assigned individual values to each item. Under Rule 2 of the Accessories (Condition) Rules, 1963, separate valuation of the parts told against assessment under the main heading. Relief under the main heading could be considered only where the value of the parts was included in the machine price and their purchase was shown to be compulsory.
Conclusion: The imported goods were not entitled to classification under the main heading and the claim for refund failed.