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Issues: Classification of imported goods under Tariff Heading 8466.93 or Tariff Heading 8207.90
In this case, the appellants imported Adaptors, Facing Heads, Tie Rods, and Micro Heads and claimed assessment under Tariff Heading 8466.93. However, the Customs Authorities assessed these goods as tools under Tariff Heading 8207.90. The Collector of Customs (Appeals) upheld the lower authority's decision, leading to this appeal. The main argument presented by the appellants was that the imported items were tool holders and not tools themselves. They pointed out that the goods were specially designed for fitment on CNC SIP Jig boring machines and were without the essential component of cutters, which actually perform the function of a tool. The catalogue also described these goods as tool holders in certain instances. On the other hand, the Departmental Representative argued that the catalogue did not explicitly state that the goods were only tool holders and categorized them under a broad description of a tooling system. The DR maintained that even when the catalogue mentioned the goods as being without cutters, it still referred to them as tools. After hearing both sides, the Tribunal examined the nature of the imported goods. The Order-in-Original indicated that the goods functioned more as holders of tools than as tools themselves. For example, the Assistant Collector described Adaptors as reducers used between the spindle and the cutter head, while Facing Heads were spare parts with a sliding arrangement for fitting boring bar holders. The Micro Head was identified as a specially designed tool holder for the SIP Jig boring machine. Considering that the catalogue described the goods as lacking essential components like cutters necessary for tooling functions, the Tribunal concluded that the items were indeed tool holders and not tools. The Tribunal referenced a previous order that classified cutter heads differently from tools, emphasizing that items without specific cutting tools could only be considered as specially designed tool holders. By analyzing the competing tariff entries of 82.07 and 84.66, the Tribunal determined that the imported goods were parts and accessories suitable for use with jig boring machines, falling under Tariff Heading 8466.93. As these tool holders were specifically designed for use with jig boring machines, the Tribunal set aside the lower authority's decision and allowed the appeal.
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