Refrigeration plants as assembled systems are not excisable goods, though individual components may still attract duty.

The note examines whether refrigeration plants erected by assessees are excisable goods under central excise law. It refers to an earlier Tribunal view that refrigeration and air-conditioning plants are systems assembled from various components and parts, not machines as a whole. It also cites a Section 37B clarification stating that such plants, viewed as systems, do not constitute excisable goods, although individual components may still be dutiable.

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Issues: Whether refrigeration plants erected by the assessees are excisable goods liable to central excise duty.

Analysis: The Tribunal noted that the question was already covered by its earlier decision holding that refrigeration and air-conditioning plants are systems assembled from various components and parts, and are not machines as a whole. It also relied on the Central Board of Excise and Customs order issued under Section 37B of the Central Excise Act, 1944, which clarified that such plants, as systems, do not constitute excisable goods, though individual components may remain dutiable.

Conclusion: Refrigeration plants erected by the assessees were held not liable to excise duty, and the issue was decided in favour of the assessees.

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