Composite machine exemption applies where separately exempt functions are combined and no clear exclusion covers the integrated equipment.

A composite machine may qualify for customs exemption where it performs two functions that are each separately exempted under the notification, and the notification does not clearly exclude the combined form. The tribunal noted that the imported dual-channel equipment carried out both EMG and EP functions, which were individually covered by the exemption table, and held that the absence of express naming of the combined machine did not defeat the exemption. The approach followed earlier tribunal reasoning on similar customs exemption language, treating the composite equipment as covered by the exempt constituent functions.

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Issues: Whether a combined machine performing two functions, both of which are separately exempted under the notification, is entitled to the benefit of the exemption.

Analysis: The imported equipment was a dual-channel system capable of performing both EMG and EP functions. The exemption under the notification extended to each of those functions separately, and the only objection was that the combined machine was not specifically named in the table. In such circumstances, where the constituent functions are individually covered and the machine merely combines them, the notification was held to apply to the composite equipment as well. Reliance was placed on the earlier tribunal view taking the same approach to a similar customs exemption notification.

Conclusion: The combined machine was held eligible for the exemption benefit, and the Revenue's appeal was dismissed.

Ratio Decidendi: A composite machine is entitled to exemption where the notification separately exempts the constituent functions it performs and the notification does not exclude the combined form in clear terms.

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