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Boiler feed pumps and condensate extraction pumps were classified by the tariff text and General Rules for Interpretation, with the HSN notes showing that sub-heading 8413 70 first covers centrifugal pumps primarily designed for handling water under CETI 8413 7010, while later entries cover other liquid-handling pumps, including boiler feed pumps. Because the goods were designed to handle water in the boiler feed system, they remained under CETI 8413 7010 and could not be shifted to CETI 8413 7095 merely because of their use in a boiler system. On that basis, Sl. No. 235 of Notification No. 12/2012-C.E. applied, and the duty demand, interest and penalties did not survive.
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