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Generate professional replies to Show Cause Notices, assessment orders, audit objections, and other legal communications using TaxTMI's AI Drafter.
Step 1 – Issue Identification & Review
The AI analyses your query, notice, order, or uploaded documents and identifies the key issues involved.
• Review the issues identified by the AI
• Add, edit, remove, or refine issues as required
Step 2 – Draft Generation
Once you approve the issues, the AI performs issue-wise legal research and prepares a structured draft response.
• Relevant statutory provisions
• Judicial precedents and Supreme Court, High Court and other citations
• Issue-wise legal analysis
• Practical arguments and supporting content
• Professionally structured draft ready for further review. 
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Issues: Whether Hammer Union, Chickson Pipes and Swivel Joints cleared as such were classifiable as machines under sub-heading 8479.10 or as parts under sub-heading 8479.90, and whether Note 4 of Section XVI applied to such classification.
Analysis: Sub-heading 8479.10 covers machines having individual functions not specified or included elsewhere in Chapter 84. The fact that the goods performed a specific function in a B.O.P. control unit did not make each item a machine by itself, since individually they could not perform the functions of a machine. The technical material also showed that the goods were parts. Note 4 of Section XVI applies when a machine consisting of individual components intended to contribute together to a clearly defined function is to be classified, and not when individual parts are cleared separately for classification.
Conclusion: The goods were classifiable as parts and not as machines, and Note 4 of Section XVI was inapplicable. The classification adopted against the assessee was upheld.
Ratio Decidendi: Note 4 of Section XVI applies only to classification of a machine or combination of components as a whole, and not to separately cleared individual parts which do not themselves perform the function of a machine.