Classification of compressor components turns on sole and principal use, with stators and rotors treated as parts of hermetically sealed compressors

Wound stators and rotors specially designed for use in hermetically sealed compressors were classifiable as parts of the compressors, not as parts of electric motors, because they were not used in any separate identifiable motor. Applying Note 2(b) of Section XVI, the Tribunal treated goods designed solely and principally for use in a particular machine as parts of that machine. Trade material, affidavits and certificates did not establish an independent motor, and earlier cases under different tariff regimes were distinguished.

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Issues: Whether wound stators and rotors manufactured for use in hermetically sealed compressors were classifiable as parts of electric motors or as parts of compressors under the Central Excise Tariff.

Analysis: The admitted factual position was that the impugned goods were not used in a separate identifiable electric motor, but were specially designed for use in hermetically sealed compressors. The Tribunal held that the trade and technical material relied upon by the appellants did not establish the existence of an independent motor as a separate , and the affidavits and certificates were of limited value because they did not fit the actual controversy. Reading the literature on hermetic compressors with Note 2(b) of Section XVI, the Tribunal found that the goods were designed solely and principally for use in a particular machine and therefore had to be classified with that machine. The reliance placed on earlier decisions dealing with different tariff regimes and different disputes was held to be distinguishable.

Conclusion: The rotors and stators were correctly classified as parts of hermetically sealed compressors and not as parts of electric motors; the Revenue's classification was upheld.

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