Classification of imported components requires proof of compatibility before consignments can be treated as complete machinery and denied exemption.

Separate low-pressure pumps imported under one bill of entry could not be clubbed with earlier spray-gun component imports and treated as complete airless spraying equipment under Heading 84.24 unless the Revenue proved compatibility and that the combined consignments formed a machine with the essential character of complete paint spraying equipment. The text notes that differing operating pressures and incompatibility between the consignments undermined the Revenue's case, while contrary material from the importer was ignored and the burden was wrongly shifted. On that basis, denial of the exemption under Notification No. 59/87-Cus., and the resulting confiscation and penalty, were unsustainable.

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Issues: Whether the low pressure pumps imported under one bill of entry could be clubbed with earlier imports of spray-gun components and treated as complete airless spraying equipment classifiable under Heading 84.24, thereby denying the benefit of Notification No. 59/87-Cus. and justifying confiscation and penalty.

Analysis: The Revenue's case rested mainly on the description in the certificate of origin, later explained by the importer as an inadvertent mistake supported by the supplier's clarification. The documents on record showed that the earlier imports and the present pumps operated at widely different pressures and were not compatible with one another so as to form a complete airless spray equipment. The material relied upon by the importer was ignored by the adjudicating authority, and the burden was wrongly shifted onto the importer instead of requiring the Revenue to establish its allegation. On the evidence, the allegation that the four consignments together constituted a complete spraying equipment was not proved.

Conclusion: The goods could not be clubbed and classified as complete paint spraying equipment under Heading 84.24, the exemption was not lawfully denied, and the confiscation and penalty were unsustainable.

Final Conclusion: The impugned order was set aside and the appeal was allowed with consequential relief.

Ratio Decidendi: Where the Revenue alleges that separately imported consignments together constitute a complete dutiable machine, it must prove compatibility and the essential character of the combined goods, and an adjudicating authority cannot sustain confiscation or penalty by ignoring contrary material and shifting the burden to the importer.

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