Tariff classification of centrifugal chillers turns on principal character and independent refrigerating function, with prior precedent followed.

An imported centrifugal chiller with an independent refrigerating function was treated as refrigerating equipment rather than air-conditioning machinery for tariff classification purposes. The Tribunal applied the principle that the principal character of the goods governs classification and found the item closer to Heading 84.18 than Heading 84.15 of the Customs Tariff Act. It also followed an earlier decision on an identical item, together with a similar ruling on a refrigeration beverage fountain, as a matter of judicial discipline and found no distinguishing features to justify departure. The Revenue's classification was therefore not sustained, and classification was accepted in favour of the assessee.

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Issues: Whether the imported centrifugal chiller was classifiable as a refrigerating equipment under Heading 84.18 or as air-conditioning machinery under Heading 84.15 of the Customs Tariff Act.

Analysis: The item was held to have an independent refrigerating function and to be closer to the description of refrigerating equipment than to air-conditioning machines. The prior decision on an identical item, together with the treatment of a similar refrigeration post mix beverage fountain in another decision, was followed on the basis of judicial discipline. The Tribunal found no reason to depart from the earlier view on classification.

Conclusion: The classification adopted by the Revenue was not sustained and the goods were held classifiable in favour of the assessee.

Ratio Decidendi: An imported centrifugal chiller having an independent refrigerating function is to be classified according to its principal character as refrigerating equipment, and a coordinate bench decision on an identical or substantially similar item must ordinarily be followed in the absence of distinguishing features.

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