Classification of uncoiler and leveller as independent machines upheld over accessory treatment under the tariff

Uncoiler and leveller were held to be independent machines with individual functions rather than accessories specially designed for a stamping press. Separate invoicing and the ability to select suitable capacity showed that they were not confined to use with one machine and could operate with other machines as well. On that basis, Heading 84.45/48 was found inapplicable, and classification under Heading 84.59 was upheld, rejecting the assessee's claim to treatment as accessories.

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Issues: Whether uncoiler and leveller were classifiable under Heading 84.45/48 as accessories or under Heading 84.59 as independent machines having individual functions.

Analysis: The items were invoiced separately and were described as capable of being selected in suitable capacity, indicating that they were not confined to one stamping press. The factual material showed that uncoiler and leveller could be used with other machines as well and were not accessories specially designed for the main machine. Since they had individual functions and did not fall within Heading 84.45/48, they were more appropriately covered by Heading 84.59.

Conclusion: The classification under Heading 84.59 was upheld and the assessee's claim under Heading 84.45/48 was rejected.

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