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Issues: Whether the lubricating oil unit for the gear reducer was classifiable as an independent machine under Heading 8479.89 or as a part of the gear unit under Heading 8413.30, and whether the Revenue was entitled to succeed in its appeal.
Analysis: The lubricating unit was found to have no independent function apart from the gear box and to operate simultaneously with it as an interdependent system. Section Note 2(a) of Section XVI required parts which are themselves goods classifiable under a specific heading of Chapter 84 or 85 to be classified under that heading, and therefore a residuary classification could not be adopted when a specific heading was available. The technical literature and supporting documents showed that the lubricating oil unit was designed for the gear box and formed part of the same functional arrangement.
Conclusion: The lubricating oil unit was not classifiable under the residuary heading claimed by the Revenue and was correctly treated as falling under the specific heading applicable to such pumps. The Revenue appeal failed.
Final Conclusion: The classification adopted by the appellate authority was sustained and the order in favour of the assessee was affirmed.