Classification of forged steel products upheld as rough forgings, denying exemption and rejecting treatment as complete machinery parts.

Forged steel products that remained at the stage of proof machining and required further machining before becoming complete articles were not treated as complete parts of machinery under Chapters 84, 85 or 87. On the facts, the goods were regarded as rough forgings rather than finished machinery parts, and there was no evidence that no further process was needed. The Department's classification under sub-heading 7326.90 was upheld, and the claimed exemption under the relevant notification was denied.

---

---

Issues: Whether forged steel products were classifiable under sub-heading 7326.90 with exemption under the relevant notification, or as parts of machinery under Chapters 84, 85 and 87.

Analysis: The item was found to be a forged product requiring further machining before it could become a complete article. The authorities below had treated the forgings up to the stage of proof machining as pieces roughly shaped, and there was no evidence showing that no further process was required. On that basis, the item could not be regarded as a complete part of machinery. The order of the Collector (Appeals) was therefore found to suffer from no infirmity.

Conclusion: The classification adopted by the Department was upheld and the assessee was not entitled to the claimed exemption.

---