Predominant-use classification for pencil line filter driers placed them under refrigerating and air-conditioning goods, not the residuary tariff entry.

Pencil line filter driers were classified on the basis of their predominant and intended use: the material showed they were used mainly, and in substance exclusively, in refrigerators and air-conditioners to arrest moisture in the cooling line, so they fell within the scope of refrigerating and air-conditioning appliances and machinery. As a result, they were classifiable under Tariff Item No. 29A of the Central Excise Tariff and not under the residuary Tariff Item No. 68.

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Issues: Whether pencil line filter driers manufactured by the petitioners were classifiable under Tariff Item No. 29A of the Central Excise Tariff or under Tariff Item No. 68 of the Central Excise Tariff.

Analysis: The classification turned on the predominant and intended use of the goods. The material placed before the Authority, including the petitioners' explanation, the D.G.T.D. communication, and the Development Commissioner's reply, supported the position that the impugned pencil line filter driers were used predominantly, if not exclusively, in refrigerators and air-conditioners to arrest moisture in the cooling line. On that basis, the goods fell within the scope of refrigerating and air-conditioning appliances and machinery and could not be treated as a residuary item.

Conclusion: The pencil line filter driers were classifiable under Tariff Item No. 29A of the Central Excise Tariff and not under Tariff Item No. 68.

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