2017 (8) TMI 988 - AT - Central Excise

Classification of goods - Controller and Field Interface Board - whether the product namely Controller and Field Interface Board manufactured by the appellant for use in lift/elevator is classifiable under Chapter Heading 8431 as lift parts as claimed by the appellant or classifiable as control panel under Chapter Heading 8537.00 as claimed by the Revenue? - Held that - the appellant s product is control panel but without the motherboard and or the processor. Even, though the control panel is without motherboard but having all other components, it will be treated as control panel, for the reason that a particular product even if it is semi processed or partially processed, it will merit classification under the head of fully finished product only - since for the control panel there is an independent tariff entry under Chapter Heading 8537, it will merit classification under its specific head, i.e. under Chapter Heading 8537 in terms of Note 2(a) of Section Notes to Section XVI of the Central Excise Tariff - appeal dismissed - decided against appellant.

Summary

Issues involved: Classification of product (Controller and Field Interface Board) under Chapter Heading 8431 as lift parts or under Chapter Heading 8537.00 as control panel.

Analysis:
1. Classification Issue: The main issue in the case was whether the product manufactured by the appellant, namely the Controller and Field Interface Board for use in lifts/elevators, should be classified under Chapter Heading 8431 as lift parts or under Chapter Heading 8537.00 as a control panel. The appellant argued that the product is solely used for lifts and lacks key components for electricity distribution, thus should be classified as a lift part. On the other hand, the Revenue contended that specific tariff entry classification prevails over being a part of a machine, thus the control panel should be classified under Chapter Heading 8537.00.

2. Appellant's Argument: The appellant's counsel emphasized that the product is exclusively designed for lifts and does not have essential components for electricity control, such as a motherboard or processor. Therefore, it should be considered a lift part under Chapter Heading 8431, not a control panel under Chapter Heading 8537.00.

3. Revenue's Argument: The Revenue's representative reiterated that even though the product is primarily used in lifts, if it can be classified under a specific tariff entry, it should be categorized accordingly. The lower authority correctly classified the product as a control panel under Chapter Heading 8537.00 based on this principle.

4. Tribunal's Decision: After considering both arguments, the Tribunal concluded that the appellant's product, despite lacking a motherboard or processor, should be classified as a control panel under Chapter Heading 8537.00. The Tribunal reasoned that even if a product is semi-processed, it should be classified under the fully finished product category. Additionally, since there is a specific tariff entry for control panels under Chapter Heading 8537, the product falls under this classification according to Note 2(a) of Section Notes to Section XVI of the Central Excise Tariff. Therefore, the Tribunal upheld the impugned order and dismissed the appeal filed by the appellant.

This detailed analysis highlights the classification dispute regarding the Controller and Field Interface Board and provides insights into the arguments presented by both parties, ultimately leading to the Tribunal's decision on the matter.