Finished filter elements classifiable as parts of filtering machines, not by constituent material, under the tariff heading.

Filter elements used in a compressor's lube oil system were held to be classifiable as parts of filtering machines under Heading 84.18, because they functioned as finished filter elements within the filtering system and were covered by tariff notes on filters and purifiers, including component parts such as perforated plates and similar items. They were not classified under Heading 73.33 as articles of iron and steel, since classification followed the commercial and functional identity of the finished item rather than the material used. The assessee's classification was affirmed and the Revenue's challenge failed.

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Issues: Whether filter elements used in the lube oil system of a compressor were classifiable as articles of iron and steel under Heading 73.33, or as parts of filtering machines under Heading 84.18.

Analysis: The filter elements were described as components placed in the lube oil system to prevent dust and foreign particles from entering the system, and the material consisted of filter paper reinforced with perforated stainless steel. The tariff notes on filters and purifiers covered filters of all types and also included parts such as perforated plates and similar components. On the facts, the item was not merely filtering material meant to be manufactured into a filter, but a finished filter element functioning as part of the filtering machine.

Conclusion: The filter elements were correctly classifiable as parts of filtering machines under Heading 84.18 and not under Heading 73.33; the Revenue's challenge failed.

Final Conclusion: The impugned classification in favour of the assessee was affirmed and the Revenue appeal stood rejected.

Ratio Decidendi: A finished filter element used as a component of a filtering system is classifiable as a part of the filtering machine, and not by the constituent material from which it is made.

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