https://www.taxtmi.com/caselaws?id=308130 Deep freezers were held to be distinct from refrigerators and air conditioners in design, utility, temperature range and power requirements, so they could not be classified under that specific entry. The later notification expressly excluded deep freezers from the air conditioner and refrigerator entry, and earlier notifications had treated them separately, supporting residuary classification. The HSN-based argument was not accepted because it was not part of the original proceedings and could not override the specific exclusion in the applicable notification. The principles of specific entry preference and the revenue's burden to establish coverage were applied, with the result that deep freezers were rightly placed in the residuary entry in favour of the assessee. en-us Wed, 30 Nov 2022 00:00:00 +0530 Tue, 12 Aug 2025 14:12:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=308130 Deep freezers were held to be distinct from refrigerators and air conditioners in design, utility, temperature range and power requirements, so they could not be classified under that specific entry. The later notification expressly excluded deep freezers from the air conditioner and refrigerator entry, and earlier notifications had treated them separately, supporting residuary classification. The HSN-based argument was not accepted because it was not part of the original proceedings and could not override the specific exclusion in the applicable notification. The principles of specific entry preference and the revenue's burden to establish coverage were applied, with the result that deep freezers were rightly placed in the residuary entry in favour of the assessee. Case-Laws VAT / Sales Tax Wed, 30 Nov 2022 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=308130