Accessory classification turns on essential function, and exemption is not lost merely because the item has multiple uses.

A music rack used to house a turntable was treated as an accessory of gramophone, record player or record-changing equipment for exemption purposes. The analysis states that once the article falls within the notified goods by its essential function, exemption under Notification No. 68/86 should not be denied merely because it may also be capable of housing other music systems. The proportionate functional use approach was rejected, and the commentary notes that classification under Chapter Heading 8522.00 supported the exemption claim rather than duty under Notification No. 160/86.

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Issues: Whether music racks manufactured by the assessee were eligible for exemption under Notification No. 68/86 as parts and accessories of gramophone, record players, record playing decks or record changer decks, or were dutiable under Notification No. 160/86.

Analysis: The music rack was found to be used for housing a turn table and was itself treated as falling under Chapter Heading 8522.00 of the Central Excise Tariff. Once the item was accepted as an accessory of the gramophone, the exemption could not be denied merely because it was capable of being used for housing other music systems as well. The proportionate functional use approach adopted to deny the exemption was therefore not accepted.

Conclusion: The music rack was held to be eligible for the benefit of Notification No. 68/86, and the denial of exemption was set aside.

Final Conclusion: The assessee succeeded on the classification and exemption issue, and the duty demand was not sustained.

Ratio Decidendi: An article remains an accessory for exemption purposes if its essential function brings it within the notified goods, and eligibility cannot be denied merely because it may also serve other uses.

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