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Issues: Whether push button switches and rotary switches without dial, knob and cover used in electric fans are classifiable as parts of fans or as switches under the tariff heading for apparatus for switching electrical circuits.
Analysis: The relevant HSN Explanatory Notes cover apparatus that make or break electrical circuits or switch from one circuit to another. The items in question were found to function as regulators controlling the speed of rotation of the fan. Their essential function was regulation of fan speed and not switching electrical circuits on or off. Since the tariff heading for switches applies only to apparatus performing a switching function, the goods could not be classified under that heading.
Conclusion: The goods were correctly classified as parts of fans and not as switches, and the Revenue's challenge failed.