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Issues: Whether evaporative air coolers and their bodies were classifiable under Heading 84.79 as machines and mechanical appliances having individual functions not specified or included elsewhere, or under Heading 84.15 as air-conditioning machines; and whether the departmental authorities could disregard the Board's circular directing classification under Heading 84.79.
Analysis: The product was treated as a desert cooler and found to be distinguishable from an air conditioner in function and value. The classification adopted by the appellate authority was supported by the HSN Explanatory Notes and was also consistent with the Board's Circular No. 27/90-CEX dated 18.07.1990, which directed classification of the impugned goods under Heading 84.79. Since that circular bound the departmental authorities, the revenue could not seek a contrary classification under the alternative heading.
Conclusion: The goods were correctly classifiable under Heading 84.79, and the revenue appeal failed.
Final Conclusion: The appeal was rejected, leaving the classification under Heading 84.79 undisturbed in favour of the assessee's position on classification and against the revenue's challenge.
Ratio Decidendi: A departmental circular directing classification of a product binds the authorities, and where the product is functionally distinct from air-conditioning machinery, it is to be classified under the tariff heading specifically covering machines and appliances not elsewhere specified.