Classification of goods as refrigerator accessories failed where no specialised design was proved; general entry applied instead.

Copper fittings, brass fittings and E.P. thermocole were not shown to be specially designed or tailor-made for refrigerators, so they could not be classified under the specific entry for refrigerator accessories. The Tribunal's own observation that the goods were used for all purposes was inconsistent with treating them as refrigerator-specific items. In the absence of evidence of specialised design, the general entry for goods used for all purposes applied. The High Court set aside the Tribunal's classification and restored the assessing authority's order, granting relief to the assessee.

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Issues: Whether copper fittings, brass fittings and E.P. thermocole were liable to be classified under the specific entry treating them as accessories to refrigerators, or under the general entry applicable to goods used for all purposes.

Analysis: The Tribunal's conclusion that the goods were used for all purposes was inconsistent with its further observation that they were designed and sold as accessories to refrigerators. There was no evidence that the items were specially designed or tailor-made for refrigerators. In the absence of such evidence, the proper approach to classification is to apply the general entry rather than a specific entry based on an assumed specialised use.

Conclusion: The classification under the specific entry could not be sustained and the order of the Appellate Tribunal was set aside. The order of the assessing authority was restored, resulting in relief to the assessee.

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