Household refrigerator classification turned on ordinary domestic use, and hotel mini-bars were treated as non-household appliances.

Imported Electrolux mini-bar refrigerators marketed for hotel use, with absorption cooling and without ordinary domestic features, were treated as refrigerators other than household type. The decisive test applied was whether the goods are generally used for household purposes, not whether they could also be used in a house or hotel room. On that basis, the goods were classified under Heading 8418.69 as non-household refrigerators and treated as eligible for concessional assessment under Notification No. 59/87-Cus., with the exemption denial set aside.

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Issues: Whether the imported Electrolux mini-bar refrigerators were classifiable as household type refrigerators or as other than household type refrigerators, and whether they were entitled to concessional assessment under Notification No. 59/87-Cus. against Sl. No. 13.

Analysis: The imported goods were described in the catalogue and the manufacturer's certificate as hotel mini-bars meant for commercial hotel use, operating on a noiseless absorption system, without compressor and without the ordinary domestic features such as egg racks, butter racks and vegetable trays. The Court held that the decisive test was whether the goods were of a kind generally used for household purposes, not whether they could possibly be used in a house or hotel room. On that basis, the mini-bars were treated as distinct from household refrigerators and were held to fall under Heading 8418.69 as refrigerators other than household type.

Conclusion: The imported mini-bar refrigerators were not household type refrigerators and were eligible for the benefit of Notification No. 59/87-Cus. The denial of exemption was set aside.

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