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        Case ID :

        1998 (9) TMI 214 - AT - Customs

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        Composite machine classification turns on principal function, so label weaving looms with design units were classified as one machine. Imported label weaving looms, together with a programming unit and camera, were treated as a composite machine because the components were intended to ...
                      Cases where this provision is explicitly mentioned in the judgment/order text; may not be exhaustive. To view the complete list of cases mentioning this section, Click here.
                        Provisions expressly mentioned in the judgment/order text.

                            Composite machine classification turns on principal function, so label weaving looms with design units were classified as one machine.

                            Imported label weaving looms, together with a programming unit and camera, were treated as a composite machine because the components were intended to work together for one clearly defined function. Applying Note 4 to Section XVI, the controlling test was the principal function of the combination, not the separate identity, pricing, or catalogue treatment of the parts. The programming unit was only a CAD and pattern workstation supporting the weaving process, and the camera was an optional aid to design work. The goods were therefore classifiable as a single machine under Heading 84.46 rather than separately under Heading 84.71 or Chapter 90, with consequential relief to the assessee.




                            Issues: Whether the imported programming unit and camera, supplied along with the label weaving looms, were to be classified separately under Heading 84.71 and Chapter 90 or treated as part of a composite machine classifiable under Heading 84.46.

                            Analysis: The imported goods were found to be intended to work together for the manufacture of labels. The programming unit was not a general purpose computer but a CAD and pattern work station meant only to create designs for the weaving process. The authorities below had relied on the separate identity of the programming unit and on the HSN notes to classify it independently, but the controlling effect of Note 4 to Section XVI was applied. Under that note, where a combination of machines consists of components intended to contribute together to a clearly defined function, the whole is classified according to that function. The clearly defined function of the imported goods was weaving of labels, and the programming unit was only an aid to that function. The separate pricing or separate catalogues did not alter the classification. The camera, being an optional feature used only to aid design work, likewise did not justify separate treatment for the purpose of classifying the composite import.

                            Conclusion: The imported goods were classifiable as a single machine under Heading 84.46 and not separately under Heading 84.71 or Chapter 90, in favour of the assessee.

                            Final Conclusion: The appeal succeeded and the classification adopted by the lower authorities was set aside, with consequential relief granted to the assessee.

                            Ratio Decidendi: When individually imported components are intended to work together for one clearly defined principal function, the whole is classified under the heading appropriate to that function rather than by isolating one component by its independent character.


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                            ActsIncome Tax
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