Tariff classification follows intrinsic character and primary function, so chillers belong under refrigerating equipment heading, not air-conditioning machinery.

Chillers manufactured by the assessee were held classifiable under Chapter Heading 84.18 as refrigerating or freezing equipment, not under Chapter Heading 84.15 as air-conditioning machines or parts. The decisive test was the goods' intrinsic character and primary function: the chillers operated through a refrigerating circuit to produce chilled water or liquid, and that essential character was not altered by later use in air-conditioning or industrial systems. End use by customers could not control classification where a specific tariff entry matched the product's essential nature. Trade parlance also supported treatment as refrigerating equipment, and the Revenue's classification under Heading 84.15 failed.

---

---

Issues: Whether chillers manufactured by the assessee were classifiable under Chapter Heading 84.18 as refrigerating or freezing equipment, or under Chapter Heading 84.15 as air-conditioning machines or parts thereof.

Analysis: The decisive consideration was the intrinsic character and primary function of the goods. The chillers were found to operate by refrigerating circuit and to produce chilled water or liquid, and that function remained unchanged merely because the chilled water was later used in air-conditioning systems or other industrial applications. The Court held that end use by customers could not determine classification where the goods otherwise fell within a specific tariff entry. It further found that Heading 84.15 covered air-conditioning machines which themselves control temperature and humidity, whereas the chiller did not perform that function. The goods were also understood in trade parlance as refrigerating equipment.

Conclusion: The chillers were classifiable under Chapter Heading 84.18 and not under Chapter Heading 84.15, and the Revenue's classification failed.

Ratio Decidendi: For tariff classification, the inherent nature and primary function of the goods prevail over end use, and a product must be classified under the specific tariff entry that matches its essential character.

---