2000 (2) TMI 429 - AT - Central Excise

Summary

Issues:
Classification of Modular System Racks Cabinets, Card frames under Heading 85.38 or Heading No. 94.03 of the Central Excise Tariff Act.

Analysis:
The appeals involved the common issue of whether the Modular System Racks Cabinets, Card frames should be classified under Heading 85.38 or Heading No. 94.03 of the Central Excise Tariff Act. The Assessee argued that the products are Modular Electronic enclosures designed for industrial electronic systems and should be classified under Heading 85.38 as parts suitable for use in electrical circuits. They emphasized that the products are not ordinary furniture but essential components for various electronic applications. The Assessee highlighted that the products are manufactured to international standards and are specifically designed for use in industrial electronic systems like D.C. Drives, Process Monitoring and Control Systems, Telecommunication Systems, and Test and Instrumentation Equipments.

On the other hand, the Revenue contended that the impugned products are primarily used as racks for housing finished products and, therefore, should be classified under Heading 94.03 as furniture. They argued that the products do not qualify as parts suitable for use with electrical apparatus under Heading 85.38. The Revenue relied on previous legal decisions and interpretations to support their classification argument. They referenced cases where similar products were categorized as furniture under the Central Excise Tariff Act.

The Tribunal considered the arguments presented by both sides. Heading 94.03 of the Central Excise Tariff Act covers "other Furniture and parts thereof," including furniture for general and special use in various settings. The Tribunal referred to the Explanatory Note of H.S.N. below Heading 94.03, which specifies the types of furniture included under this heading. The Tribunal noted that Chapter 94 excludes furniture specifically designed as parts of apparatus under certain headings related to electrical and electronic equipment. Based on the evidence and arguments presented, the Tribunal concluded that the impugned products were not classifiable under Heading 85.38 as parts for electrical apparatus. Therefore, the Tribunal rejected the appeal filed by the Assessee and allowed the appeals filed by the Revenue, classifying the products under Heading No. 94.03 as furniture.

This detailed analysis of the legal judgment highlights the classification dispute regarding the Modular System Racks Cabinets, Card frames under the Central Excise Tariff Act and the Tribunal's decision based on the arguments presented by both parties and relevant legal provisions.