Classification of air-conditioning ducts as system parts upheld, rejecting the revenue's tariff view and granting consequential relief.

Ducts fabricated from galvanised iron sheets and used in an air-conditioning system were treated as parts of that system for tariff purposes. The CESTAT followed its earlier view that such goods are classifiable under sub-heading 7308.50 rather than sub-heading 7304.10. The revenue's classification was rejected, the assessee's lower duty treatment was accepted, and consequential relief followed.

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Issues: Whether ducts fabricated out of galvanised iron sheets were classifiable under sub-heading 7304.10 or under sub-heading 7308.50 as part of the air-conditioning system.

Analysis: The dispute on classification was treated as covered by an earlier decision of the same Bench. The reasoning adopted was that ducts fabricated from galvanised sheets, when used in an air-conditioning system, are to be regarded as part of that system for tariff purposes, and the earlier view had been followed in subsequent cases.

Conclusion: The goods were held classifiable under sub-heading 7308.50, and not under sub-heading 7304.10, in favour of the assessee.

Final Conclusion: The classification adopted by the revenue was set aside and the assessee's claim to the lower duty treatment was accepted with consequential relief.

Ratio Decidendi: Goods manufactured as ducts for use in an air-conditioning system are to be classified as parts of that system when the governing precedent so treats them for tariff purposes.

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