TaxTMI 
TaxTMI 
1997 (3) TMI 298
X X X X Extracts X X X X
X X X X Extracts X X X X
...., for the Respondents. [Order per : Shiben K. Dhar, Member (T)]. - This appeal is directed against the order dated 16-9-1988 of Collector of Customs (Appeals), Bombay. 2. The appellants imported what they claimed to be a complete CLU Process Plant for Steam Blasting for the production of stainless steels and other alloy steels. Hence this Process Plant is based on the use of steam as....
X X X X Extracts X X X X
X X X X Extracts X X X X
.... Arguing for the appellants, the Learned Advocate submits that what they imported was a complete system as such which had to be disassembled for the purpose of importation as the entire machine could not be imported as such. In fact, all these parts were assembled in their factory to make a complete system. In this view of the matter, going by the Rules of interpretation and Section notes mac....
X X X X Extracts X X X X
X X X X Extracts X X X X
....ted in 1994 (74) E.L.T. 5. 5. We have heard both sides. 6. The main ground on which the authorities below have held against the appellants is that the goods are supplied as parts with separate values. It was contended before us that the customs authorities had asked them to show them separate value, though they had placed orders for a complete system. The agreement with the supplie....
X X X X Extracts X X X X
X X X X Extracts X X X X
....appropriate to the whole machine. The authorities below have not discussed this basic question before applying the separate tariff headings to the parts. However, we must make it clear that, as pleaded by the Learned DR even though with the help of Section notes and Rules of interpretation such parts put together could be assessed as machine for the purpose of classification. It would not follow t....