1997 (9) TMI 237 - AT - Customs

Summary

Issues: Classification of imported goods under Customs Tariff - Electro Magnetic Clutches

Comprehensive Analysis:

Issue 1: Classification of Goods
The appeal concerns the classification of goods, specifically Electro Magnetic Clutches imported by M/s. M. M. Enterprises. The importer sought classification under sub-heading No. 8505.20 of the Customs Tariff, which covers electro magnetic couplings, clutches, and brakes meant for car air conditioning systems. The Asstt. Collector of Customs initially classified the goods under sub-heading No. 9806.00, considering them as part of the air conditioning system. However, the Collector of Customs (Appeals) disagreed and held that the clutches were assessable under sub-heading No. 8505.20.

Issue 2: Arguments Presented
During the hearing, the Appellant Revenue argued that the electro magnetic clutches were essential for car air conditioning systems as they transmitted power from the engine to the compressor. The Revenue contended that the clutches fell under Heading No. 85.05, sub-heading No. 8505.20 of the Customs Tariff. The Collector of Customs (Appeals) had emphasized the function of the clutches in engaging and disengaging the compressor from the crankshaft.

Issue 3: Legal Interpretation
The Revenue referenced Note 4 under Section XVI of the Tariff, which states that machines with individual components contributing to a defined function should be classified accordingly. However, the Tribunal noted that the crankshaft of the car engine and the air conditioning compressor did not constitute a single machine or a combination of machines under this note. Heading No. 98.06 covers parts of machinery, but the Tribunal found that the electro magnetic clutches were not part of the air conditioning machine and should not be classified under sub-heading No. 9806.00.

Judgment
After considering all relevant facts and circumstances, the Tribunal upheld the decision of the Collector of Customs (Appeals) and rejected the appeal filed by the Revenue. The Tribunal concluded that the electro magnetic clutches should be classified under sub-heading No. 8505.20 of the Customs Tariff, as they were not considered part of the air conditioning machine but rather an accessory to the system, not falling under Heading No. 9806.00 for parts of machinery.

This detailed analysis highlights the key arguments, legal interpretations, and the final judgment regarding the classification of the imported goods under the Customs Tariff.