Classification of complete instruments prevails over parts heading where revenue fails to prove they are machinery components.

Imported differential pressure indicators were held to be complete instruments capable of independent use, based on the catalogue and record, rather than mere parts of a poly extruder malt pressure control system. Because the Revenue did not establish that the goods were only machinery components, classification under Heading 98.06 was not justified. The goods were accordingly classifiable under Sub-heading 90.26, and the departmental appeal was rejected, sustaining the lower appellate authority's classification.

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Issues: Whether the imported differential pressure indicators were classifiable under Heading 98.06 as parts of machinery or under Sub-heading 90.26 as complete instruments.

Analysis: The goods were found, on the basis of the catalogue and the record, to be self-contained differential pressure indicators and controllers suitable for a wide variety of applications. The Revenue failed to substantiate that the goods were merely parts of a poly extruder malt pressure control system so as to attract Heading 98.06. In the absence of material showing that the imported items were parts of machinery, and since they were complete instruments by themselves, the classification under Heading 98.06 was not justified.

Conclusion: The goods were correctly classifiable under Sub-heading 90.26 and not under Heading 98.06, in favour of the assessee.

Final Conclusion: The departmental appeal was rejected and the classification adopted by the lower appellate authority was sustained.

Ratio Decidendi: Where imported goods are complete instruments in themselves and the revenue does not establish that they are merely parts of machinery, they cannot be classified under the parts heading reserved for such machinery components.

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