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Issues: (i) Whether a screen stretcher is classifiable under Heading 8442.30 of the Customs Tariff as machinery, apparatus or equipment for preparing or making printing blocks, plates or other printing components, or under residuary Heading 8479.89; (ii) Whether, on such classification, the goods were entitled to the benefit of Notification No. 59/87-Cus. dated 1-3-1987.
Issue (i): Whether a screen stretcher is classifiable under Heading 8442.30 of the Customs Tariff as machinery, apparatus or equipment for preparing or making printing blocks, plates or other printing components, or under residuary Heading 8479.89.
Analysis: The screen stretcher was used to stretch wire mesh with even tension, which was an essential step in the preparation of printing screens/blocks. The apparatus was not a general appliance with an individual function falling outside the specified headings, but a device integrally connected with the making of printing components. On that functional basis, it answered the description of apparatus for preparing or making printing blocks and related components.
Conclusion: The screen stretcher was correctly classifiable under Heading 8442.30 and not under residuary Heading 8479.89, in favour of the assessee.
Issue (ii): Whether, on such classification, the goods were entitled to the benefit of Notification No. 59/87-Cus. dated 1-3-1987.
Analysis: The notification extended the concession to goods falling under sub-heading 8442.30. Since the screen stretcher was held to be classifiable under that sub-heading, the condition for exemption was satisfied.
Conclusion: The assessee was entitled to the benefit of Notification No. 59/87-Cus. dated 1-3-1987.
Final Conclusion: The impugned order was set aside and the appeal succeeded on the classification issue as well as on the consequential exemption claim.
Ratio Decidendi: A goods entry must be determined by its essential and integrated function, and an apparatus used as a necessary step in making printing components falls within the specific tariff heading for such preparation rather than the residuary heading.