1986 (1) TMI 230

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....use in transformers. In addition, they possess specially rounded edges to prevent the insulation of the wire inside the transformer from being damaged. The strips, after cutting to required length, are used as spacers between high and low-voltage coils, inside the transformers. 2. The lower authorities have assessed the goods under heading 85.18/27(1) of the C.T.A. It is the case of the Department that this heading, inter alia, covers "insulating fittings for electrical equipment" which is a specific entry for the subject goods. The Department relies on Note 2 to Section XVI of the C.T.A. The appellants' case is that heading 85.01(1) covers Transformers and since the goods are specially designed components for power transformers, they sh....

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....aterial in evidence. Both sides drew our attention to portions of the catalogue in support of their respective case. The learned representative of the Department maintained that according to the foreign Manufacturer's statement in the catalogue, insulation was the main function of the goods imported. 4. We have given our earnest consideration to the matter. Explanatory Notes to the C.C.E.N., though not incorporated into the Customs Tariff Act, yet possess persuasive value unless the context of the C.T.A. indicates to the contrary. It could also be said that though the orders-in-revision passed by the Central Government are not binding on this Tribunal, yet they too possess persuasive value. However, we find that in the present case we ha....

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....s the insulation material used for the radia spacers must not only have maximal electrical strengths but also: (a) high compression strength. (b) minimal plastic deformation under high pressure. (c) high resistance to permanent heat under pressure." The above extracts leave no doubt in our mind that the declared purpose for which the foreign manufacturer designed the subject Transformerboard strips is to insulate high-voltage coils from low voltage coils inside the transformer. We have been told by both sides that but for this insulation provided by these strips the two coils might come in contact with each other and result in blow-out of the transformer. To act as a spacer or wedge between the two coils of the transformer is a ....