Specific tariff classification for machinery parts prevailed, securing customs exemption for imported grinding sets.

Imported grinding sets used with general purpose crushing and grinding machinery were treated as parts classifiable under Heading 9806.00 read with sub-heading 8479.82 because the tariff contained a specific entry for the machinery, making recourse to the composite-goods or essential-character approach unnecessary. On that basis, the goods fell within the exemption for parts of machinery specified under Heading 84.79 in Notification No. 69/87-Cus. dated 1-3-1987. The reassessment and refund denials were set aside, and customs relief was granted.

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Issues: Whether the imported grinding set was classifiable as parts of machinery under Heading 98.06 read with sub-heading 8479.82 and entitled to exemption under Notification No. 69/87-Cus. dated 1-3-1987.

Analysis: The goods were found to be grinding set imported for use with general purpose crushing and grinding machinery, and the tariff contained a specific heading for such machines under sub-heading 8479.82. In view of the specific tariff entry, there was no occasion to resort to Section 19 or to treat the goods as composite goods governed by the essential character rule. Since the machine fell under sub-heading 8479.82, its parts were held to be classifiable under Heading 98.06 read with that sub-heading. The notification expressly covered parts falling under Heading 98.06 of goods specified under Heading 84.79, and the imported goods answered that description.

Conclusion: The imported goods were correctly classifiable under Heading 9806.00 read with sub-heading 8479.82 and were eligible for exemption under Notification No. 69/87-Cus. dated 1-3-1987.

Final Conclusion: The orders denying reassessment and refund were set aside, and the appellant obtained the consequential customs relief claimed.

Ratio Decidendi: Where the tariff contains a specific heading for the machine, its parts are to be classified correspondingly under the parts heading and the exemption attached to that entry cannot be denied by invoking a more general composite-goods approach.

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