Functional classification of machine parts: specially designed castings used in air-conditioning machinery fell under Heading 84.15.

Fully machined gun metal castings of pipe flanges, made to buyer specifications and drawings and used in an air-conditioning plant, were classifiable as parts of air-conditioning machinery under Heading 84.15. Their commercial description as refrigeration pipe flanges did not change their functional identity, because goods specially designed for and actually used as components of a particular machine are classified according to that machine. The Revenue's classification was therefore upheld and the assessee's claimed heading rejected.

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Issues: Whether fully machined castings of pipe flanges in gun metal, manufactured to specifications and drawings for use in an air-conditioning plant, were classifiable under Heading 84.15 as parts of air-conditioning machinery or under the tariff heading claimed by the assessee.

Analysis: The goods were supplied according to the buyer's specifications and drawings and were admittedly used in an air-conditioning plant. Their commercial description as refrigeration pipe flanges did not alter their actual use in the air-conditioning system. On the facts recorded, the goods were not meant for a refrigeration system in the abstract, but were components intended for air-conditioning machinery. Goods specially designed for and used as parts of a particular machine are to be classified according to that functional identity.

Conclusion: The goods were correctly classifiable under Heading 84.15 as parts of air-conditioning machinery, and the assessee's classification was rejected.

Final Conclusion: The impugned order was set aside and the classification adopted by the Revenue was upheld.

Ratio Decidendi: Goods specially designed for and actually used as components of a particular machine are classifiable as parts of that machine, notwithstanding a broader or different descriptive label.

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