Valve classification under customs tariff stayed under valves heading; compressor-part treatment and exemption benefit were denied.

Valves specially designed for compressors remained classifiable under CTH 8481.80 because taps, cocks and valves stay in that heading even when made for use on a particular machine. The HSN Explanatory Notes recognise only limited exceptions, such as suction or pressure valves for air or gas compressors, and no evidence showed the goods met that description. The claim for exemption under Notification No. 132/87 also failed because the notification's exclusionary scheme did not extend benefit to the goods. The goods were therefore treated as valves, not compressor parts, and exemption was unavailable.

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Issues: Whether the imported goods, being valves specially designed for compressors, were classifiable under CTH 8414.90 as parts of compressors or under CTH 8481.80 as valves, and whether they were eligible for the benefit of Notification No. 132/87.

Analysis: Valves are specifically covered by CTH 8481.80, and the HSN Explanatory Notes make it clear that taps, cocks and valves remain classified in that heading even if specialised for use on a particular machine or apparatus. The Notes carve out only limited exceptions, such as suction or pressure valves for air or gas compressors, which may fall under the heading for compressors. No evidence was produced to show that the goods answered that description. The claim for notification benefit also failed in view of the specific exclusionary scheme in Notification No. 132/87.

Conclusion: The goods were correctly classifiable under CTH 8481.80 and were not eligible for classification as compressor parts under CTH 8414.90. The exemption benefit was not available to the respondent.

Final Conclusion: The revenue appeal succeeded and the order granting relief to the respondent was set aside.

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