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AI Drafter - (New and Powerful) ✕ Generate professional replies, appeals, opinions to Show Cause Notices, assessment orders, audit objections, and other legal communications using TaxTMI's AI Drafter.
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Issues: Whether imported loaded printed circuit board assemblies forming part of a Digital Control Programmer for a sintering furnace were classifiable as parts of the furnace under Heading 85.14, as printed circuits under Heading 85.34, or as parts of an automatic data processing machine under Heading 84.73.
Analysis: The imported goods were found to be printed circuit board assemblies of the Digital Control Programmer and not parts of the sintering furnace itself. Classification depended on the nature and function of the machine to which the goods belonged, not on the particular end-use to which the assessee put that machine. The catalogue did not show that the Digital Control Programmer was meant solely for sintering furnaces. Since the assemblies were solely for use in the Digital Control Programmer, Note 2(b) of Section XVI required them to be classified with that machine. The finding that Heading 85.34 covered the goods was rejected because that heading applied only to plain printed circuit boards and not loaded or assembled boards.
Conclusion: The goods were correctly classified under Heading 84.73. The assessee's claim for classification under Heading 85.14 failed, and the Revenue's contention succeeded.
Final Conclusion: The original assessment was upheld, the refund claim failed, and the appellate order was set aside.
Ratio Decidendi: Parts that are solely or principally suitable for use with a particular machine are to be classified with that machine, and loaded printed circuit boards are not covered by the tariff entry for plain printed circuit boards.
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