Machine-tool parts classification under Chapter 84 confirmed for imported dies, with Heading 98.06 and exemption benefit upheld.

Imported thread rolling dies and similar tools were held to be classifiable as parts of machine tools under Chapter 84, not as interchangeable tools under Heading 82.07, because their specific use with machine tools brought them within the earlier Sarada Industries line of decisions and the coverage of parts and accessories under Heading 84.66. Section Note 1(k) of Section XVI did not defeat classification under Chapter 84 once the goods were properly treated as machine-tool parts. On that basis, eligibility for Heading 98.06 and Notification 156/86 followed, and the revenue challenge failed.

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Issues: Whether the imported tools and dies were classifiable as interchangeable tools under Heading 82.07 or as parts of machine tools under Chapter 84, with consequential eligibility for Heading 98.06 and Notification 156/86.

Analysis: The imported goods were identical to items considered earlier in the Sarada Industries line of decisions. Those decisions had held that such thread rolling dies and similar implements are functionally parts of machine tools and not interchangeable tools. The reasoning turned on the specific use of the goods with machine tools, the exclusionary effect of Section Note 1(k) of Section XVI only after a proper Chapter 82 classification is reached, and the specific coverage of parts and accessories under Heading 84.66 for machines of Headings 84.56 to 84.65. The earlier High Court and Tribunal rulings were treated as binding and applicable to the present goods.

Conclusion: The goods were correctly classified under Chapter 84 as parts of machine tools and not under Heading 82.07 as interchangeable tools. The benefit of Heading 98.06 and Notification 156/86 was therefore available, and the revenue appeal failed.

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