2002 (4) TMI 157 - AT - Central Excise

Summary

Issues Involved:
1. Classification of rail assembly front seat adjuster/assembly slider seat and rear back seat lock assembly under Central Excise Tariff.
2. Determination of whether the items in question are parts or accessories.
3. Appropriate Chapter Heading for classification under Central Excise Tariff.

Issue-Wise Detailed Analysis:

1. Classification of Rail Assembly Front Seat Adjuster/Assembly Slider Seat and Rear Back Seat Lock Assembly:
The primary dispute in the appeal concerns the Central Excise Classification of specific car seat components. Initially classified under Chapter Heading 87.08, the impugned orders reclassified them under Chapter Heading 94.01. The Deputy Commissioner of Central Excise, in Order-in-Original Nos. 233-234/99, dated 24-11-99, concluded that the goods in question are parts of motor vehicle seats and should be classified under Chapter Heading 94.01, as they are integral to the seats of Maruti vehicles and are essential for the seats' completeness and marketability.

2. Determination of Whether the Items in Question Are Parts or Accessories:
The appellants argued that the items are accessories of motor vehicles and not parts of seats. They contended that the rail assembly front seat adjuster/assembly slider seat and rear back seat lock assembly are designed to enhance the efficiency and convenience of the seats but are not essential components. The seats are complete and functional without these items, which are optional features for cars. The appellants supported their argument by citing the Supreme Court decision in M/s. Mehra Brothers v. Joint Commercial Officer, which clarified that accessories are adjuncts or additions for the convenient use of another part of the vehicle and do not need to be essential for the vehicle's operation.

3. Appropriate Chapter Heading for Classification Under Central Excise Tariff:
The Tribunal examined the rival Chapter Headings 87.08 and 94.01. Chapter Heading 87.08 covers "Parts and accessories of the motor vehicles of Heading Nos. 87.01 to 87.05," while Chapter Heading 94.01 pertains to "Seats (other than those of Heading No. 94.02), whether or not convertible into beds and parts thereof." The Tribunal noted that the classification by lower authorities was based on the premise that the goods in question are integral parts of car seats and are marketed as such. However, the Tribunal found that these items are not essential components of the seats but are accessories that enhance the seats' functionality and convenience. The Tribunal cited the Supreme Court's judgment in Mehra Bros. and the Larger Bench decision in Fykays Engineering Pvt. Ltd., which distinguished between parts and accessories, emphasizing that accessories are additions for better use, while parts are essential pieces.

Conclusion:
The Tribunal concluded that the items in question are accessories, not parts of seats, and should be classified under Chapter Heading 87.08 as "accessories of the motor vehicle." The Tribunal highlighted that Chapter Heading 87.08 is broader in scope, covering all accessories of motor vehicles, and supported this classification with the Supreme Court's ruling in Mehra Bros., which stated that an accessory of a part of an automobile qualifies as an automobile accessory. Consequently, the Tribunal set aside the impugned orders and allowed the appeal, granting consequential relief to the appellants.