Exemption for integral dental chair components turns on functional necessity, not an unraised alternative tariff classification.

Dental spittoon bowls of opal glass were analysed as component parts of dentists' chairs for exemption purposes. On the evidence, including catalogues, photographs and institutional certificates, the spittoon was treated as integral to the dental unit and necessary for practical dental treatment. The commentary notes that the alternative tariff classification of the bowls was of limited relevance where the exemption under Notification No. 66/88 extended to component parts of goods covered by Notification No. 65/88, and no different classification case had been advanced below. The stated ratio is that exemption cannot be denied to an integral component merely because another tariff heading is suggested without being the basis of the proceedings.

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Issues: Whether the dental spittoon bowls of opal glass were eligible for exemption as component parts of dentists' chairs under the relevant exemption notifications.

Analysis: The dental chair was accepted as classifiable under Heading 90.18, and the record showed that the chair was normally supplied with a spittoon bowl as part of the dental unit. The evidence, including catalogues, photographs and certificates from dental institutions, supported the finding that a dental spittoon is integral to a dentists' chair and is necessary for its practical use in dental treatment. The dispute over whether the bowls might otherwise fall under another tariff heading was held to be of limited relevance, because the exemption under Notification No. 66/88 applied to component parts of the goods covered by Notification No. 65/88, and the Revenue had not put forward a different classification case before the lower authorities.

Conclusion: The spittoon bowls were held to be integral component parts of dentists' chairs and were entitled to exemption; the objection to exemption failed.

Final Conclusion: The impugned order was set aside and the appeal was allowed on the footing that the disputed spittoon bowls qualified for the claimed exemption as parts of exempt dental chairs.

Ratio Decidendi: Where a disputed article is established on evidence to be an integral component of an exempted machine or equipment, exemption for component parts cannot be denied merely because an alternative tariff classification is suggested but was not the basis of the proceedings below.

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