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Compressors for car ACs classified as gas compressors, not parts; tax classification norms applied.

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....Imported compressors for car air conditioning systems classified under CTH 8414 8011 as gas compressors for air conditioning equipment, not CTH 8415 9000 as parts of air conditioning machines. Classification based on Harmonized System Nomenclature and Explanatory Notes to Section XVI. No estoppel in taxation matters regarding prior classification claims. Predominant use test from Westinghouse case not applicable as it pertained to different Section Note. Revenue failed to establish case, impugned order set aside by Appellate Tribunal, appeal allowed.....