2004 (1) TMI 83 - HC - Customs

Summary

Issues:
Classification of imported spring plates under Heading 73.20 or Heading 8414.19 of the Customs Tariff Act.

Analysis:
1. The petition raised the issue of classifying spring plates imported by the Petitioners under Heading 73.20 as claimed by the Revenue or under Heading 8414.19 as claimed by the Petitioners.

2. The Petitioners manufacture air and gas compressors and import spring plates made of high carbon steel sheets for specific applications in compressors. These spring plates are not off-the-shelf items and are designed based on specific drawings for each compressor.

3. The Assistant Collector of Customs classified the imported spring plates under Heading 73.20, leading to the petition challenging this classification.

4. The relevant Customs Tariff Headings include 73.20 for springs and leaves for springs of iron or steel, and 8414.19 for parts of air or gas compressors.

5. The classification issue involves Section XV and XVI of the Customs Tariff Act, with specific notes excluding identifiable parts of compressors from Section XVI and categorizing springs under Section XV.

6. Springs plates, although designed for compressors, are considered parts of general use under Section XV, not falling under Section XVI covering compressors.

7. The Assessing Officer acknowledged the specialized design of the spring plates but classified them under 73.20 based on the Section Notes.

8. Legal arguments included referencing the Brussel's Convention on the Harmonised Commodity Description and Coding System, the decision in CCE v. Wood Craft Products Limited, and a CEGAT judgment on classifying compressor parts under Heading 84.14.

9. The Petitioners argued that the spring plates, not being conventional springs, should be classified under Heading 8414.90 for compressor parts.

10. The Respondents supported the Assessing Officer's classification under 73.20 based on the Customs Tariff Act notes.

11. The Court noted that the spring plates, designed for specific compressor use, are considered parts of general use under Section XV, despite being specialized for compressors classified under Heading 84.14.

12. The Court rejected the argument that spring plates are not springs in the traditional sense, as they are explicitly covered under Heading 73.20 of the Customs Tariff Act based on the Section Notes.

13. Consequently, the petition was dismissed, upholding the classification of spring plates under Chapter Heading 73.20 of the Customs Tariff Act.