Correlating imported forgings with claimed machinery parts requires strict proof to secure customs exemption.

Imported alloy steel forgings were not shown to correlate sufficiently with the claimed heat exchanger parts, so they could not be treated as parts for customs exemption. The bill of entry and invoice described the goods as forgings, while the drawings, invoice particulars and DGTD materials did not establish that the imported items had, without further processing, assumed the character of the specific parts claimed. Because the goods had already left customs charge, a high degree of proof was required to prove correlation with the finished product, and that burden was not discharged. The claim for exemption therefore failed.

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Issues: Whether the imported alloy steel forgings could be correlated with the claimed parts of heat exchangers so as to merit classification as parts and the benefit of exemption under the customs notification.

Analysis: The description in the bill of entry and invoice identified the goods as alloy steel forgings. The lower authorities had rejected the claim because the drawings, invoice particulars and DGTD materials did not satisfactorily correlate the imported goods with the specific parts claimed. The affidavit produced at the appellate stage only stated generally that the items were complete parts used in chemical machinery, but did not furnish sufficient particulars to establish that the goods imported had, without further processing, assumed the character of the claimed parts. Since the goods had already left customs charge, a high degree of proof was required to establish correlation with the finished product, and that burden had not been discharged.

Conclusion: The claim for treating the goods as parts of heat exchangers and for extending the exemption was not proved, and the rejection of the appeal was justified.

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