Tariff classification of electrical control panels: specific heading 85.37 prevails over treatment as air-conditioner parts.

Electrical control panels supplied with roof-top mounted package air conditioner units were held classifiable under Heading 85.37, because the panels were themselves goods specifically covered by that tariff heading. Note 2(a) to Section XVI required classification in the specific heading, and Note 2(b) could not displace that rule for parts already covered elsewhere in Chapters 84 or 85. Rule 1 of the Interpretative Rules and the HSN Explanatory Notes on electric control boards and panels supported this classification, and the Board's circular also excluded such panels from Heading 84.15. The panels were therefore not to be treated as parts of the air-conditioning package unit, and the classification dispute was decided in favour of the assessee.

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Issues: Whether electrical control panels manufactured and supplied with roof top mounted package air conditioner units were classifiable under Heading 85.37 or as parts of the air conditioning package unit under Heading 84.15.

Analysis: The electrical control panels were undisputedly goods included in Heading 85.37 of the Central Excise Tariff and were therefore required to be classified in that heading under Note 2(a) to Section XVI. Note 2(b) applies only to parts not themselves covered by any heading in Chapters 84 or 85, and could not override Note 2(a). Rule 1 of the Rules for the Interpretation of the Schedule also required classification according to the terms of the headings and relevant section notes. The HSN Explanatory Notes specifically treated boards and panels for electric control as falling under Heading 85.37. The Board's circular also placed electrical and control panels in the list of items not classifiable under Heading 84.15, and no technical material was produced to justify a different classification.

Conclusion: The electrical control panels were correctly classifiable under Heading 85.37 and not as parts of the air conditioning package unit under Heading 84.15.

Final Conclusion: The appeal was allowed and the assessee succeeded on the classification dispute.

Ratio Decidendi: Where a component is itself covered by a specific tariff heading, it must be classified in that heading under Note 2(a) to Section XVI, even if it is specially designed for use with a particular machine or supplied along with it.

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