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Paddle wheel aerators used in aquaculture do not fall within the specific agricultural machinery heading (HSN 8436) because that entry is limited to machineries used in agriculture, horticulture, forestry, poultry and bee keeping; ejusdem generis and noscitur a sociis principles and the popular meaning of "agriculture" were applied, and notification definitions are confined to their own notifications. A press release is not binding for tariff classification. Absent a specific tariff entry, the aerators are classed under the residual machinery entry (machines not specified elsewhere) and subject to GST under the residual entry.
Paddle wheel aerators used in aquaculture do not fall within the specific agricultural machinery heading (HSN 8436) because that entry is limited to machineries used in agriculture, horticulture, forestry, poultry and bee keeping; ejusdem generis and noscitur a sociis principles and the popular meaning of "agriculture" were applied, and notification definitions are confined to their own notifications. A press release is not binding for tariff classification. Absent a specific tariff entry, the aerators are classed under the residual machinery entry (machines not specified elsewhere) and subject to GST under the residual entry.
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