Machinery-parts classification for tablet-making punches and dies prevails over Chapter 82 treatment where no independent function is proved.

Punches and dies used with tablet-making machines were held classifiable as parts of machinery under CET sub-heading 8485.90, rather than as punches and dies under sub-heading 8207.00. Note 2(a) to Section XVI was treated as inapplicable because it applies only to goods independently falling under Chapters 84 or 85 other than the excluded headings, and these goods were found to be independent goods under Chapter 82. The departmental contention that the items performed cutting, perforating, stamping or hole-punching functions was not established, while their use as spare parts of tablet-making machines supported classification under the specific machinery-parts heading.

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Issues: Whether punches and dies manufactured for use in tablet making machines are classifiable under CET sub-heading 8485.90 as parts of tablet making machines, or under CET sub-heading 8207.00 as punches and dies.

Analysis: Note 2(a) to Section XVI of the Central Excise Tariff applies only to goods which are themselves independent goods falling under Chapters 84 or 85 other than Heading 84.85 and 85.48. The goods in question were found to be independent goods falling under Chapter 82 and not goods whose classification was governed by that note. The departmental case that the goods performed functions such as perforating, cutting, pressing holes or stamping was not established. The goods were used along with tablet making machines and were treated as spare parts of such machines. Heading 84.85 covers machinery parts not specified or included elsewhere in the chapter.

Conclusion: The goods were correctly classifiable under CET sub-heading 8485.90 and not under sub-heading 8207.00.

Ratio Decidendi: A product used as a part of tablet making machinery, and not shown to be independently classifiable elsewhere, is to be classified under the specific machinery-parts heading rather than as punches and dies under Chapter 82.

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