Tariff classification of air coolers placed under residual heading, not plastic articles or air-conditioning machines

Air washers were held not classifiable as articles of plastic under Chapter 39 merely because their body was plastic, since the remaining components were not plastic and the goods were essentially air coolers of large capacity. They were also rejected as air-conditioning machines under Heading 84.15 because they did not answer that tariff description in the relevant sense. The appropriate classification was Heading 84.79 for machines having individual functions not elsewhere specified, with consequential relief granted to the assessee.

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Issues: Whether air washers were classifiable under Chapter 39 as articles of plastic, under Heading 84.15 as air-conditioning machines, or under Heading 84.79 as machines having individual functions.

Analysis: The goods were found to be air coolers of large capacity. Only the body was made of plastic and the remaining parts were not plastic, so the goods did not qualify as articles of plastic. As the goods were essentially air coolers and not air-conditioning machines in the relevant tariff sense, the more appropriate classification was under Heading 84.79 for machines having individual functions not elsewhere specified.

Conclusion: The classification under Chapter 39 and Heading 84.15 was rejected, and the goods were held classifiable under Heading 84.79 in favour of the assessee.

Final Conclusion: The appeal succeeded and the lower classification was set aside with consequential relief.

Ratio Decidendi: For tariff purposes, an article is not classifiable as a plastic article merely because its body is made of plastic, and goods functioning as air coolers may fall under the residuary heading for machines having individual functions rather than under the heading for air-conditioning machines.

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