Springs specially designed for compressors remain classifiable as springs, not compressor parts, under the tariff.

Imported spring plates and springs, even if specially designed for use in a compressor, remain classifiable as springs under Heading 7320.90 because springs are treated as parts of general use under the tariff notes and HSN guidance. They do not become compressor parts merely by specialised application, so classification under Heading 8414.90 was rejected. As a result, the exemption available to compressor components under Notification No. 111/86-Cus. did not apply.

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Issues: Whether the imported spring plates and springs, claimed to be compressor components, were classifiable as parts of compressors under Heading 8414.90 and eligible for exemption under Notification No. 111/86-Cus., or were correctly classifiable as springs under Heading 7320.90 as parts of general use.

Analysis: The goods were examined in the light of the Section Notes to Sections XV and XVI of the Customs Tariff Act, 1975 and the HSN guidance. Springs, including specialised springs meant for a particular machine, remain classifiable under Heading 73.20 as springs and not under the heading of the machine of which they form a part. Section Note 2(b) to Section XV treats springs as parts of general use, and Section Note 4 extends the reference to base metal to alloys. Since the goods were found to be springs and not compressor parts classifiable under Heading 8414.90, the exemption notification applicable to component parts of compressors did not apply.

Conclusion: The imported goods were correctly classified under Heading 7320.90 and were not entitled to exemption under Notification No. 111/86-Cus.; the contention for classification under Heading 8414.90 was rejected.

Ratio Decidendi: Springs remain classifiable as springs under the tariff heading specifically covering springs, even if specially designed for use with a particular machine, and do not become parts of that machine merely by reason of specialised use.

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