Process cooling chillers classified as refrigerating equipment under Heading 84.18, not air-conditioning machines.

Liquid chillers used for process cooling were held to fall under Heading 84.18 as refrigerating equipment because their prime function is to produce chilled water for refrigeration and industrial process cooling. Earlier Tribunal rulings on the same classification issue were followed, and the chillers used for injection moulding machines, drying machines and chemical plant were found to perform the same essential function. They were therefore excluded from Heading 84.15 as air-conditioning machines, and the Revenue's challenge failed.

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Issues: Whether liquid chillers used for process cooling were classifiable under Heading 84.18 as refrigerating equipment or under Heading 84.15 as air-conditioning machines.

Analysis: The dispute was treated as already settled by earlier Tribunal decisions holding that the prime function of chillers is to produce chilled water for refrigeration and process cooling, which brings them within Heading 84.18 and excludes them from Heading 84.15. The goods in the present matter performed a similar function for injection moulding machines, drying machines and chemical plant, so the earlier reasoning was applied on the same factual and legal footing.

Conclusion: The goods were correctly classifiable under Heading 84.18 and not under Heading 84.15, so the Revenue's challenge failed.

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