Graphilor classification as heat exchanger parts prevailed over mineral substance classification in the tariff dispute.

Graphilor tubes specially designed as parts of heat exchangers were treated as machinery parts under Heading 8419.90 rather than articles of mineral substance under Heading 6815.10. The Tribunal relied on an earlier ruling on graphilor blocks, noting that artificial graphite impregnated with phenolic resins is not an article of mineral substance and, absent any contrary higher forum decision, the same classification principle applied. The imported goods were therefore classified as heat exchanger parts, and the Revenue's challenge failed.

---

---

Issues: Whether the imported graphilor tubes were classifiable as parts of heat exchangers under Heading 8419.90 or under Heading 6815.10 as articles of mineral substance.

Analysis: The Tribunal noted that the facts were similar to an earlier decision holding that graphilor blocks, being made of artificial graphite impregnated with phenolic resins and not articles of mineral substances, were parts of heat exchangers falling under the relevant heading for machinery parts. In the absence of any contrary decision by a higher forum, the Tribunal followed that ratio for the present classification dispute.

Conclusion: The imported goods were held classifiable as parts of heat exchangers, and the Revenue's appeal was rejected.

Ratio Decidendi: Where graphilor goods are specially designed as parts of heat exchangers and are not articles of mineral substance, they are classifiable as machinery parts rather than under the heading for articles of stone or other mineral substance.

---