Classification of cooling-tower parts follows machine-specific use, not general-use goods, and the Revenue challenge failed.

Cooling-tower parts specially suited for use solely or principally with a particular machine were held classifiable with that machine under Note 2 to Section XVI of the Central Excise Tariff Act, rather than as goods of general use under Heading 3925.99. Because no evidence showed that the items were parts of general use, and the Revenue itself suggested they might not be marketable as independent goods, the classification adopted in the impugned order was upheld and the Revenue's appeal was rejected.

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Issues: Whether the impugned products used as parts of cooling towers were classifiable under Heading 3925.99 as claimed by the Revenue or under Heading 84.19.

Analysis: The relevant test was whether the goods were parts suitable for use solely or principally with a particular kind of machine so as to fall with the machine under Note 2 to Section XVI of the Schedule to the Central Excise Tariff Act. The exception for parts of general use under Section XV was also considered. No evidence was produced to show that the goods were parts of general use, and the Revenue itself indicated that the goods may not be available in the market. On that basis, the classification adopted in the impugned order was found to be correct.

Conclusion: The goods were not classifiable under Heading 3925.99 and the Revenue's appeal was rejected.

Ratio Decidendi: Where goods are shown to be specially suited as parts of a particular machine and are not established to be parts of general use, they are to be classified with the machine under Note 2 to Section XVI of the Schedule to the Central Excise Tariff Act.

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