Tariff classification of composite machine-tool parts turns on specific headings, with exemption relief limited to goods under the parts heading.

A composite clutch and brake assembly used solely with a specified machine tool was not treated as a mere clutch or shaft coupling under Heading 8483.60; it was classified as a part suitable solely for use with that machine under Heading 8466.94. Clutch disc and brake disc were also not complete clutches or couplings and were classified as parts under Heading 8483.90. Notification No. 156/86 applied only to the extent the goods fell within Heading 8466.94, so exemption relief was limited accordingly, with partial relief granted to the assessee.

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Issues: (i) Whether the imported clutch and brake assembly was classifiable under Heading 8483.60 of the Customs Tariff Act, 1985 or under Heading 8466.94 as a part suitable for use solely with machine tools of Heading 84.62. (ii) Whether clutch disc and brake disc were classifiable under Heading 8483.60 or under Heading 8483.90 as parts. (iii) Whether the goods were entitled to the benefit of Notification No. 156/86 dated 01-03-1986.

Issue (i): Whether the imported clutch and brake assembly was classifiable under Heading 8483.60 of the Customs Tariff Act, 1985 or under Heading 8466.94 as a part suitable for use solely with machine tools of Heading 84.62.

Analysis: Note 2(a) of Section XVI applies only where the goods are themselves included in a heading of Chapters 84 or 85. The imported item was a composite clutch and brake assembly and could not be treated as a mere clutch or shaft coupling within Heading 8483.60. Since it was used solely with the relevant machine tool, it fell within the residuary rule for parts suitable for use solely or principally with a particular machine.

Conclusion: The clutch and brake assembly was not classifiable under Heading 8483.60 and was correctly classifiable under Heading 8466.94, in favour of the assessee.

Issue (ii): Whether clutch disc and brake disc were classifiable under Heading 8483.60 or under Heading 8483.90 as parts.

Analysis: The clutch disc and brake disc were not complete clutches or shaft couplings. They were only parts of the clutch assembly and therefore did not fit the specific description of Heading 8483.60. Their proper classification was as parts under Heading 8483.90.

Conclusion: Clutch disc and brake disc were classifiable under Heading 8483.90, in favour of the assessee.

Issue (iii): Whether the goods were entitled to the benefit of Notification No. 156/86 dated 01-03-1986.

Analysis: The notification covered component parts of machine tools for working metals. The distinction between component parts and spare parts was held to be inapplicable in the context of this notification, and the benefit followed the classification of the goods as parts of machine tools. Relief was available only to the extent the goods were found classifiable under Heading 8466.94.

Conclusion: The benefit of Notification No. 156/86 was available only to the extent the goods were classifiable under Heading 8466.94, in favour of the assessee to that limited extent.

Final Conclusion: The appeal succeeded in part, with the principal assembly classified as a part of the machine tool and the disputed discs classified separately as parts, resulting in partial relief on classification and exemption.

Ratio Decidendi: A composite imported part that is not encompassed by a specific tariff heading must be classified under the rule for parts suitable solely or principally for a particular machine, and exemption notifications covering component parts may extend to spare parts where the notification uses the expression in isolation.

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