Tribunal classifies Chillers under Heading 84.18, overturning Commissioner's order.

The Tribunal allowed the appeal filed by the Appellants, setting aside the Commissioner's order and classifying the Chillers manufactured by M/s. Carrier Aircon Ltd. under Heading 84.18 of the Central Excise Tariff Act. The Tribunal determined that the Chillers, designed to produce chilled water using a refrigeration circuit, should be classified under 84.18 based on their specific function, in line with the Explanatory Notes of HSN and a Board circular clarifying the classification of refrigerating appliances.

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Issues involved: Classification of Chillers under Central Excise Tariff Act.

Summary:
The appeal involved the classification of Chillers manufactured by M/s. Carrier Aircon Ltd. under Heading No. 84.18 or 84.15 of the Central Excise Tariff Act. The Appellants argued that the Chillers are functionally designed to produce chilled water and should be classified under 84.18, while the Commissioner classified them under 84.15 as part of central air-conditioning systems.

The Senior Advocate for the Appellants argued that the primary function of the Chiller is to produce chilled water/liquid, and its use in central air-conditioning systems does not change its classification under Heading 84.18. The Revenue contended that the Chillers are integral parts of air-conditioning systems, but did not dispute the function of the Chillers as explained by the Appellants.

The Tribunal observed that the Chillers should be classified under Heading 84.18 as they are designed to produce chilled water using a refrigeration circuit, which aligns with the specific Heading. The Explanatory Notes of HSN also support this classification, stating that components of air-conditioning machines are classified under specific headings regardless of their subsequent use in air-conditioning systems. The Tribunal referred to a Board circular clarifying that refrigerating appliances cover equipment maintained at sub-zero temperatures for freezing perishable food.

In conclusion, the Tribunal allowed the appeal filed by the Appellants and set aside the Commissioner's order, classifying the Chillers under Heading 84.18 of the Central Excise Tariff Act.

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