Composite machine classification requires machines fitted together as one whole; coordinated plant operation alone is not enough.

For tariff classification under Heading 84.59, machines qualify as a composite machine only if they are fitted together to form a whole in the manner required by Section Note 3 of Section XVI. Mere coordinated operation or interdependence in an integrated plant is insufficient where the items remain separately identifiable and are not mounted together on a common base, frame or housing. On that basis, the screen changer, grinder and force feed device were treated as separate items rather than part of one composite machine, while the extruder was recognised as a single machine by itself.

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Issues: Whether the imported screen changer, grinder and force feed device, along with the extruder, were classifiable as a composite machine under Heading 84.59(2), or were separately classifiable under Heading 84.59(1).

Analysis: The essential question was whether the imported items were fitted together to form a whole so as to satisfy the test of a composite machine under Section Note 3 of Section XVI. Although the items worked in coordination and were necessary for the overall process of converting nylon waste into nylon chips, they were not incorporated one in the other, mounted on one another, or mounted on a common base, frame or housing. The extruder was a single machine by itself, while the remaining items, though inter-dependent in the plant, retained their separate character and did not constitute components of one single machine for tariff purposes.

Conclusion: The items other than the extruder were not classifiable as part of a composite machine under Heading 84.59(2) and were correctly classified separately under Heading 84.59(1), against the assessee.

Ratio Decidendi: For tariff classification as a composite machine, the machines must be fitted together to form a whole in the manner contemplated by the relevant section note and explanatory notes; mere interdependence or coordinated operation in an integrated plant is insufficient.

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