Tariff classification of air-conditioning parts: heat exchanger assemblies fell under Heading 8415.90, not Heading 8419.50.

Imported heat exchanger assemblies used as condenser and evaporator components of air-conditioning machines were held classifiable under Heading 8415.90 as parts of such machines. Reading the tariff entries with the HSN Explanatory Notes and Note 2(a) to Section XVI, the text of Heading 8419.50 was treated as covering only heat exchanger units not used for domestic purposes. The goods' technical description as heat exchangers did not justify classification under the lower-rate heading when their true character was parts of air-conditioning equipment. The classification under Heading 8415.90 was therefore upheld.

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Issues: Whether the imported heat exchanger assemblies were correctly classifiable under Heading 8415.90 as parts of air-conditioner machines rather than under Heading 8419.50.

Analysis: The imported goods were found to be parts of air-conditioning machines. The competing tariff entries were read along with the Explanatory Notes to the HSN and Note (2)(a) to Section XVI. On that reading, parts of air-conditioning machines fall under Heading 8415.90, while Heading 8419.50 covers only heat exchanger units not used for domestic purposes. The goods were also described in the technical documents as condenser and evaporator assemblies, and their description as heat exchangers was not accepted for claiming a lower rate under Heading 8419.50.

Conclusion: The goods were not classifiable under Heading 8419.50 and were rightly assessed under Heading 8415.90. The classification adopted by the authorities was upheld and the appeal failed.

Ratio Decidendi: Where the legal text of a tariff heading excludes goods used for domestic air-conditioning machinery, a sub-heading under that heading cannot be invoked to classify such goods contrary to their true character and the governing explanatory notes.

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