Classification of air conditioning parts under Heading 84.15 upheld for identifiable components used with air handling units.

Identifiable components of an air handling unit used solely or principally with air conditioning machinery were held classifiable under Heading 84.15 by application of Note 2(b) to Section XVI. The Tribunal treated the main section, coil section and filter section as parts of the air handling unit, and therefore as parts of the air conditioning machine rather than goods falling under Heading 7308.90 or 7322. The classification adopted by the department was upheld, as the disputed items were recognised as specific machinery parts and not as separate articles under the competing headings.

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Issues: Whether parts of an air conditioning machine, namely the main section, coil section and filter section, were classifiable under Heading 84.15 or under Heading 7308.90/7322.

Analysis: The appeal turned on the classification of components manufactured for and used as parts of an air handling unit used with air conditioning machines. The Tribunal followed its earlier decision holding that an air handling unit, being a specific part of an air conditioning machine and used solely or principally with such machines, fell under Heading 84.15 by virtue of Note 2(b) to Section XVI. The records also showed that the disputed items were recognisable as identifiable parts of the air handling unit, supporting classification with the air conditioning machinery rather than under the competing headings claimed by the assessee.

Conclusion: The disputed parts were correctly classifiable under Heading 84.15 and not under Heading 7308.90/7322; the challenge by the assessee failed.

Final Conclusion: The classification adopted by the department was upheld and the appeal was dismissed.

Ratio Decidendi: Identifiable components used solely or principally with air conditioning machinery are classifiable under the specific tariff heading applicable to that machinery by virtue of Note 2(b) to Section XVI.

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