TaxTMI 
TaxTMI 
1997 (12) TMI 420
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....der per : Shiben K. Dhar, Member (T)]. - The appellants imported Minimum Pressure Valve. These were assessed to duty under Heading 84.81. Subsequently, however, the importers, claiming correct classification under CTH 8414.90, filed a refund claim claiming this classification together with benefit of Notification 172/89 and Notification 60/87, dated 1st March, 1987. This claim was rejected ....
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.... Note 2(a) clearly indicates that parts which are goods included in any of the headings of Chapter 84, 85 (other than Heading 84.85 and 85.48) are in all cases to be classified in their respective headings, he held that since valves are specifically covered under 8481, even if they were parts of the machine, they cannot be classified as parts of the machine in view of Note 2(a) of Section XVI. In ....
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....d inclusion connotes extension and therefore one may take it that "Pressure Reducing Valves and Thermostatically Controlled Valves" may not be flattered by the condition of these being suitable for pipes, boiler shells, tanks or the like. 6. In this context, therefore, it is necessary to examine the exact characteristics of the valves such as have been imported. The Literature placed at Page....
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....tion valve for reducing the pressure of valves and maintaining the reduced pressure at a fairly constant level. In terms of HSN Notes also, therefore, it would be necessary to arrive at an exact finding as to nature and characteristics of the impugned valves. HSN Notes have great pursuasive value and have to be accepted unless the context otherwise requires. It is correct that if there is a confli....