Independent filtering function controls tariff classification; jet air filters in a flour mill fall under Heading 8421, not parts of milling machinery.

Jet air filters used in a flour mill were classified under Heading 8421 as filtering or purifying machinery because they performed an independent dust-separating and air-cleaning function in the pneumatic conveying system. The material showed that they did not carry out any milling activity, and the HSN notes supported classification of air filters and cyclones used to remove dust from exhaust air under Heading 8421. Section Note 2(a) required goods already covered by a Chapter 84 heading to remain there, while Note 2(b) applied only to true parts used solely or principally with a particular machine. The goods were therefore treated as accessories rather than parts, and Heading 9806 was held inapplicable.

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Issues: Whether jet air filters used in a flour mill are classifiable under Heading 8421 as filtering or purifying machinery for gases, or under Heading 9806 as parts of machinery used in the milling industry, and whether they were entitled to the claimed exemption notification benefit.

Analysis: The goods functioned to separate dust and clean air in the pneumatic conveying system, and the material placed on record showed that they did not perform any milling function. The HSN explanatory notes stated that air filters and cyclones used to filter dust from exhaust air of operating machines are outside Heading 8437 and fall under Heading 8421. Section Note 2(a) of Section XVI required goods already covered by a Chapter 84 heading to be classified in that heading, while Section Note 2(b) applied only to parts usable solely or principally with a particular kind of machine. On that basis, the jet filters were at best accessories and not parts of the milling machine, so Heading 9806 was not attracted.

Conclusion: The impugned goods were correctly classifiable under Heading 8421 and not under Heading 9806.

Final Conclusion: The Revenue succeeded, the classification adopted by the lower authority was reversed, and the appellate order in favour of the importer was set aside.

Ratio Decidendi: A machine performing an independent filtering function in a milling installation is classifiable under its own tariff heading, and only goods that are true parts, not mere accessories, can be brought under the heading for parts of milling machinery.

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