https://www.taxtmi.com/caselaws?id=53277 Copper coil performing the heat-exchange function was treated as the evaporator, while the steel tank was only a receptacle, so the department's attempt to classify the entire tank-and-coil assembly as an evaporator was rejected. The analysis also notes that a cooling unit classification under Item 29A(3) was a different basis from the one alleged in the notice, and the department could not deny Rule 56C on a fresh classification theory not put forward earlier. Rule 56C was stated to apply only where the goods received by the primary manufacturer in fact fell under Item 68; otherwise duty lay on the actual manufacturer, not the receiver. en-us Wed, 07 Jan 2004 00:00:00 +0530 Tue, 12 Oct 2010 13:10:17 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=53277 Copper coil performing the heat-exchange function was treated as the evaporator, while the steel tank was only a receptacle, so the department's attempt to classify the entire tank-and-coil assembly as an evaporator was rejected. The analysis also notes that a cooling unit classification under Item 29A(3) was a different basis from the one alleged in the notice, and the department could not deny Rule 56C on a fresh classification theory not put forward earlier. Rule 56C was stated to apply only where the goods received by the primary manufacturer in fact fell under Item 68; otherwise duty lay on the actual manufacturer, not the receiver. Case-Laws Central Excise Wed, 07 Jan 2004 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=53277