Classification of industrial sewing-machine parts and motors follows machine-specific headings; exemption applies only to the notified tariff entry.

Industrial sewing-machine spare parts were held classifiable under Heading 8452.90, not Heading 8483.90, because the sewing-machine heading specifically covered parts and related accessories, while the transmission heading did not fit the imported goods. Electric motors imported with the machines were classified with the sewing machines under Section Note 2, as they were intended for use solely with those machines; the stands were classified under Heading 8452.40 as sewing-machine furniture. Exemption under Notification No. 172/89-Cus. applied to the spare parts because they fell within Heading 8452.90, but not to the stands, which were outside the notified entry.

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Issues: (i) Whether the spare parts of industrial sewing machines were classifiable under Heading 8452.90 of the Customs Tariff or under Heading 8483.90; (ii) whether the electric motors and stands imported along with the sewing machines were to be classified separately or with the sewing machines; and (iii) whether the spare parts and the stand were eligible for exemption under Notification No. 172/89-Cus. dated 29-5-1989.

Issue (i): Whether the spare parts of industrial sewing machines were classifiable under Heading 8452.90 of the Customs Tariff or under Heading 8483.90.

Analysis: Heading 8452 covers sewing machines and specifically includes furniture, bases, covers specially designed for sewing machines and other parts of sewing machines under the relevant sub-headings. Heading 8483 relates to transmission and power-transmission items and their parts, which did not fit the imported goods. The imported items were essential maintenance spares of industrial sewing machines and were specifically covered by the sewing-machine heading.

Conclusion: The spare parts were correctly classifiable under Heading 8452.90 and not under Heading 8483.90, in favour of the assessee.

Issue (ii): Whether the electric motors and stands imported along with the sewing machines were to be classified separately or with the sewing machines.

Analysis: Section Note 2(a) of Section XVI requires goods included in any heading of Chapter 84 or 85 to be classified in their respective headings, while Section Note 2(b) provides that other parts suitable for use solely or principally with a particular machine are to be classified with that machine. The record showed that the motors and stands were meant for the industrial sewing machines, were not separately presented as independent imports, and were imported with the machines for their intended use. The stands also fell within the express tariff coverage for furniture of sewing machines.

Conclusion: The electric motors were to be classified with the sewing machines, and the stands were classifiable under Heading 8452.40; the Revenue's claim for separate classification was rejected, in favour of the assessee.

Issue (iii): Whether the spare parts and the stand were eligible for exemption under Notification No. 172/89-Cus. dated 29-5-1989.

Analysis: The notification granted concessional duty to goods falling under Heading 8452.90, excluding parts of household sewing machines. Since the spare parts were classifiable under Heading 8452.90, they satisfied the notification. The stand, however, fell under Heading 8452.40 and was outside the specified entry.

Conclusion: The spare parts were eligible for the notification benefit, but the stand was not, partly in favour of the assessee.

Final Conclusion: The assessee succeeded on the principal classification dispute concerning the spare parts and the motors, while the stand remained outside the exemption entry, and the Revenue's appeal failed.

Ratio Decidendi: Where goods are imported along with a machine and are specially designed for its use, they are to be classified with the machine under the relevant tariff provisions and section notes, and exemption is available only if the goods fall within the exact notified tariff entry.

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