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Classification of imported goods as parts under Heading No. 84.66 for benefit of Notification 156/86 vs. duty assessment at 60% + 45% + additional duty under Heading No. 8207.40 or 8207.90 CTA/Heading No. 82.07 CET. Analysis: The appeal concerned the classification of imported goods, such as tap ribs, taps, knurling dies, punches, ceramic inserts, and die assembly, as either parts falling under Heading No. 84.66 or interchangeable tools under Heading No. 8207.40 or 8207.90 CTA/Heading No. 82.07 CET. The Collector (Appeals) classified the items as parts of machine tools under Chapter 84, granting the benefit of Heading 98.06 with Customs Notification 156/86. However, the Collector classified the items for CVD under Chapter 82.07 at a 20% rate, not the claimed 15% rate, but granted benefits for basic customs duty and auxiliary duty. The revenue contended that the imported items were interchangeable tools, not parts of machine tools, and thus ineligible for the benefit under Chapter 98.06. They argued that Section Note 1(k) of Section XVI excludes articles of Chapter 82 or 83 from Chapter 84, preventing the concessional rate of duty. Additionally, Chapter Note 2 to Chapter 82 stipulates that parts of base metal of articles of Chapter 82 should be classified with the articles they belong to, except for specified parts and tool holders for hand tools. The advocate for the assessee cited a judgment by the Madras High Court and the Tribunal, which held that the items in question were parts of machines, not interchangeable tools. The High Court's ruling was based on detailed technical analysis, classifying the items under Heading 84.45/48 of the Customs Tariff Act, analogous to Item 72(3) of the Indian Customs Tariff. The Tribunal and the High Court's decisions were deemed binding and applicable in the present case. After careful consideration of the judgments, it was concluded that the items were parts of machine tools, falling under Chapter 84, and not interchangeable tools under Chapter 82. The classification under Heading 84.66 for parts and accessories suitable for use with machines of specific headings was found appropriate. The Tribunal's previous rulings and the Supreme Court's approval of the judgments reinforced the decision. Consequently, the impugned order was upheld, as it was correctly decided by the Madras High Court and followed by the Tribunal, leading to the dismissal of the appeal.
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