Composite machine classification denied for tension stringing equipment, but reel elevator accepted separately under Heading 84.22.

Distinct units used together in a stringing operation did not become a composite machine merely because they worked in coordinated performance; classification had to follow the individual character and tariff description of each item. On that basis, the imported tension stringing equipment was not accepted as one composite machine under Heading 84.22, and Note 3 of Section XVI did not apply. However, the reel elevator was separately treated as a jack and classified under Heading 84.22. The assessment of the remaining items was left undisturbed, and the appeal succeeded only to that limited extent.

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Issues: (i) Whether the imported tension stringing equipment constituted one composite machine classifiable under Heading 84.22 of the Customs Tariff and covered by Note 3 of Section XVI; (ii) Whether the reel elevator was classifiable under Heading 84.22 as a jack, with the remaining items continuing to be assessable as ordered by the Collector.

Issue (i): Whether the imported tension stringing equipment constituted one composite machine classifiable under Heading 84.22 of the Customs Tariff and covered by Note 3 of Section XVI.

Analysis: The equipment consisted of distinct units such as the puller, tensioner, running-out blocks and allied articles, each performing a separate function in the stringing operation. Their coordinated use for a common purpose did not make them parts of a single composite machine. Heading 84.22 was directed to lifting, handling, loading or unloading machinery, and the imported main machines did not answer that description. Note 3 of Section XVI therefore had no application.

Conclusion: The claim that the entire consignment was classifiable as one composite machine under Heading 84.22 was rejected, and that part of the assessment stood in favour of Revenue.

Issue (ii): Whether the reel elevator was classifiable under Heading 84.22 as a jack, with the remaining items continuing to be assessable as ordered by the Collector.

Analysis: The assessee specifically pressed only the reel elevator for separate treatment as a jack. On that limited item, the Tribunal accepted the plea and directed assessment under Heading 84.22. For the other items, no basis was found to disturb the Collector's classification.

Conclusion: The reel elevator was allowed to be assessed under Heading 84.22, while the remaining items were left undisturbed.

Final Conclusion: The appeal succeeded only to the limited extent of the reel elevator, and the assessment of the rest of the goods was sustained.

Ratio Decidendi: Distinct machines used together for a common operation do not become a composite machine merely because they co-operate in coordinated performance; classification must follow the individual character and tariff description of the goods.

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