Principal use classification places atomizer wheel under the machine heading, while the exact sub-heading remains undecided.

An atomizer wheel shown by the catalogue and surrounding material to be an essential part of a suspended particle drying plant was classified with that plant under Heading 84.17, because parts suitable solely or principally for use with a particular machine cannot be taken to the residuary Heading 84.65 in the absence of contrary evidence. The precise sub-heading under 84.17 was not finally determined, as the record did not establish exclusive use for milk processing and the import documents lacked model or part numbers; that issue was left to the original authority on reassessment.

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Issues: (i) Whether the imported Atomizer Wheel was classifiable under Heading 84.17 instead of the residuary Heading 84.65. (ii) Whether the item fell under sub-heading 84.17(1) or 84.17(2).

Issue (i): Whether the imported Atomizer Wheel was classifiable under Heading 84.17 instead of the residuary Heading 84.65.

Analysis: The item was shown by the catalogue and the surrounding material to be an essential part of a suspended particle drying plant and a part suitable for use principally with the drying plant described. In the absence of contrary evidence from the department, and applying the principle that parts suitable solely or principally with a particular machine are to be classified with that machine, the residuary heading could not be preferred.

Conclusion: The item was held classifiable under Heading 84.17 and not under Heading 84.65, in favour of the assessee.

Issue (ii): Whether the item fell under sub-heading 84.17(1) or 84.17(2).

Analysis: The record indicated possible use in drying plant for milk as well as other spray-drying applications. The material before the Tribunal was not sufficient to record a specific finding that the machinery was exclusively for processing milk, and the absence of model or part numbers in the import documents also left the precise sub-heading unresolved.

Conclusion: The appropriate sub-heading was left to the original authority for determination on reassessment.

Final Conclusion: The classification was shifted from the residuary entry to Heading 84.17, but the exact sub-heading was not finally determined and the matter was sent back for reassessment.

Ratio Decidendi: Parts suitable solely or principally for use with a particular machine are classifiable with that machine, and a residuary heading cannot be invoked when such principal suitability is established.

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