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Issues: Whether the product known as Weather Maker was classifiable as an evaporative type of cooler for the purpose of exemption under Notification No. 73/89-C.E. dated 1-3-1989 as amended, despite having an additional heating facility.
Analysis: The product was held to be a cooler with a blower fitted in the cabinet and a heating mechanism operating only as an attachment. The principal purpose of the machine was to blow cool air, and the heating facility did not alter its essential character. Applying Chapter Note 7 of Chapter 84, a machine used for more than one purpose is to be treated as if its principal purpose were its sole purpose. Since the classification under Heading 84.79 was not in dispute, the only question was whether the additional heating feature removed the product from the category of evaporative type of coolers. The conclusion was that it did not. The cited Supreme Court decision concerned a different product and did not assist the appellant.
Conclusion: The product remained an evaporative type of cooler and was not entitled to the claimed exemption.
Final Conclusion: The exemption denial was upheld and the appeal failed.
Ratio Decidendi: Where the principal purpose of a multi-function machine remains that of an evaporative cooler, an additional heating attachment does not change its classification or take it outside the exclusion applicable to evaporative type coolers.