In Brief
BHEL (Bharat Heavy Electricals Limited) cleared boiler components that were imported/manufactured. The Revenue assessed duty under sub-heading 8402.90 (parts, at 15% duty), but BHEL and the lower appellate authorities classified them under sub-heading 8402.10 (complete boilers, at 10% duty). The Supreme Court held that components essential to construct and operate a boiler—such as the drum, feed pipes, economizer, super-heater, and valves—must be classified as the complete boiler machine itself when transported unassembled for convenience, not as separate parts. The Court dismissed the Revenue's appeal, upholding the lower classification."
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