Tariff classification of bellows as part of a measuring instrument follows the instrument-specific heading, not a general parts heading

Bellows forming an identifiable part of a measuring instrument are to be classified under the tariff heading applicable to the instrument and its parts, where they perform that instrument function. The lower authorities treated the bellows as separate goods, but the Tribunal accepted their role as an integral component of the measuring instrument. Classification therefore followed Heading 90.29(1) read with Heading 90.24(1), rather than the more general Tariff Heading 83.01/15(2), in favour of the assessee.

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Issues: Whether bellows connected to a measuring instrument were classifiable as a part of that instrument under Heading 90.29(1) read with Heading 90.24(1), or under Tariff Heading 83.01/15(2).

Analysis: The dispute turned on the character of the goods as an integral part of a measuring instrument. The assessment made by the lower authorities proceeded on the view that the bellows, though connected with the instrument, were not part of it. The Tribunal accepted the position that the goods were to be considered in the light of their function as part of the measuring instrument and held that the classification had to follow the appropriate tariff headings for such a part.

Conclusion: The bellows were held classifiable under Heading 90.29(1) read with Heading 90.24(1), and not under Tariff Heading 83.01/15(2), in favour of the assessee.

Ratio Decidendi: Where goods form an identifiable part of a measuring instrument and perform that function, tariff classification must follow the heading applicable to the instrument and its parts rather than a more general heading applied by the lower authority.

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