Tariff classification turns on specific heading description; limitation for duty demand follows the statute in force during the relevant period.

Goods specifically described in Heading 84.83 were to be classified there, while items not exactly answering that description could fall under Heading 84.66 as parts and accessories suitable for the machines concerned. Bearings, housings, pulleys, couplings and claw clutches were treated as falling within Heading 84.83, but shafts and pinions were classified under Heading 84.66. The limitation question was governed by Section 11A as it stood during the relevant period, so the date of the order-in-appeal had no bearing on computation of the six-month demand period. The classification was modified only for shafts and pinions, and the limitation objection was rejected.

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Issues: (i) Whether the products in dispute were to be classified partly under Heading 84.83 and partly under Heading 84.66 of the Central Excise Tariff Act, 1985. (ii) Whether the demand of duty for the six-month period had to be reckoned from the date of the impugned order-in-appeal.

Issue (i): Whether the products in dispute were to be classified partly under Heading 84.83 and partly under Heading 84.66 of the Central Excise Tariff Act, 1985.

Analysis: The tariff scheme required goods specifically covered by Heading 84.83 to be classified there, while articles not answering that specific description could fall back under Heading 84.66 as parts and accessories suitable for use with the machines concerned. On that basis, bearings, housings, pulleys, couplings and claw clutches were treated as covered by Heading 84.83, whereas shafts and pinions, not exactly matching the named goods under that heading, were held to fall under Heading 84.66.

Conclusion: The classification was upheld in part and modified in part, with bearings, housings, pulleys, couplings and claw clutches under Heading 84.83 and shafts and pinions under Heading 84.66.

Issue (ii): Whether the demand of duty for the six-month period had to be reckoned from the date of the impugned order-in-appeal.

Analysis: The limitation for demand was governed by Section 11A of the Central Excises and Salt Act as it stood during the relevant period, and not by the date of the appellate order. The date of the order-in-appeal therefore had no bearing on computation of limitation.

Conclusion: The plea on limitation was rejected.

Final Conclusion: The appeal succeeded only to the extent of reclassification of shafts and pinions, while the remaining classification and the limitation objection were rejected.

Ratio Decidendi: Goods specifically described in a tariff heading must be classified under that heading, and limitation for demand must be determined under the governing statutory provision in force during the relevant period.

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