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2026 (2) TMI 990

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.... Act". The issue raised by M/s PEE AAR AUTOMOTIVE TECHNOLOGIES PRIVATE LIMITED, E-311, E-312, General Zone, Industrial Area Ghiloth, Shahjahanpur, ALWAR- 301706, Rajasthan (hereinafter "the applicant") is fit to pronounce advance ruling as they have deposited prescribed Fee under CGST Act and it falls under the ambit of the Section 97(2) given as under: (a) classification of goods and/or services or both (e) determination of the liability to pay tax paid or deemed to have been paid A. SUBMISSION OF THE APPLICANT (in brief):- Brief facts of the case: The Applicant, M/s PEE AAR Automotive Technologies Pvt. Ltd., is presently engaged in the manufacturing and supply of Condenser Fans and Blower. These fans & blower are designed for air circulation in a bus engine system and do not incorporate any temperature control. The manufacturing takes place entirely at the Applicant's own production facility at Ghiloth, Alwar, Rajasthan, which is equipped with dedicated machinery, motor assembly units, blade fabrication lines, and shroud fitting stations to ensure quality and uniformity in production. The condenser fan & blower produced by the Applicant has a ....

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....P (incl. All Taxes) Rs. 4771 per pc Made In: India MFG BT Pee Aar Automotive technology Pvt. Ltd. Mfg Date. 11-08-2025 Contact No. "9921672712 ([email protected])" 1.2. Seeking Classification and Rate Clarity Under the GST Regime The advance ruling is being sought in relation to the classification of Condenser Fan and Blower under the GST Tariff Schedule. The Applicant is engaged in the ongoing manufacture and supply of this product and is seeking a ruling to determine whether the appropriate classification is under Heading 8414 as a Industrial fans and blowers (specifically under HSN 8414.59.30) or any alternate classification. The objective of the ruling is to obtain legal clarity and certainty on the applicable GST classification and tax rate for Condenser Fan and Blower, considering its Industrial fans and blowers. B. INTERPRETATION AND UNDERSTANDING OF APPLICANT ON QUESTION RAISED (IN BRIEF) 1.3. Description of the Product - Condenser Fan The product manufactured by the Applicant is a Condenser Fan designed for use in heavy-duty bus rooftop and engine applications. It consists of an electric motor that drives aerodynamic blades h....

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.... follows: Technical Specification of Condenser Fan SI No SPECIFICATION ASSY COMBINATION PRODUCT PHOTOS END APPLICATION A MOTOR:                                                                           1 Motor Construction:2Parts 2 Motor Type: PMDC 24V4 Pole 3 Motor Operating Voltage: 9V to 26 V 4 Operating Temperature :- 30 Deg C to + 85 Deg C 5 Motor Housing Treatment: CED Coating (Black) 6 All finishing treatments: Complianceto 2000-53- EC (ELV) 7 Bearing: Ball Bearing B Shroud Axial   1 Raw Material: Nylon 6 30 GF   2 Operating Temperature :- 30DegCto+85DegC C Fan Blade 305mm Pusher         1 Fan Type: Blowing, No of Blades: 5 2 Fan Mounting: External Circlip with Locking Pin. 3 Fan Blade OD: Dia 305mm 4 Fan material: Nylon 630GF ....

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....kg to 12 kg, determined by motor size and shroud construction. • The blades are lightweight yet durable, capable of withstanding prolonged high- speed rotation. • Packaging is carried out in heavy-duty corrugated cartons with internal foam padding to prevent transit damage. • Each carton is labelled with product description, HSN code, quantity, batch number, and manufacturing date, ensuring traceability. 1.8. Performance Chart having Input power, output power, airflow, & specific energy consumption of the Product - Condenser Fan Parameter Value Unit Remarks Motor Voltage (DC) 12 V Nominal supply voltage Motor Current Draw 11 A At rated load Electrical Input Power 132 W  Vx A Estimated Motor Efficiency 80 % Typical for small DC motors Mechanical Output Power 106 W Input x Efficiency Impeller Speed 2,150 RPM At rated voltage Airflow Capacity 2,100 m3/hr Measured free delivery Specific Energy Consumption 0.0505 W*h/m3 Output power = airflow Intended Use Ventilation / Air Movement - Non-domestic application The low out....

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.... Blower with end application is as follows: SI.No. SPECIFICATION ASSY COMBINATION PRODUCT PHOTOS END APPLICATION A MOTOR:                                                                             1 Motor Construction : 3 Parts 2 Motor Type: PMDC 24V 2 Pole 3 Motor Operating Voltage: 9V to 26 V 4 Operating Temperature: - 30 Deg C to +85 Deg C 5 Motor Housing Treatment: CED Coating (Black) 6 All finishing treatments : Compliance to 2000- 53-EC(ELV) 7 Bearing: Ball Bearing B BLOWER BASE AND COVER   1 Raw Material: PP 20 GF   2 Operating Temperature: - 30 Deg C to +85 Deg C   C BLOWER WHEEL:       1 Blower Type: Blowing 2 Blower Mounting: External Circlip with D Section Mounting 3 Blower Wheel OD: Dia 105mm 4 Blower Wheel material: ....

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....ss the blower's full operating range of 9V to 26V DC, even under extreme temperatures from -30°C to +85°C. 2.4. Intended Use and Target Market of the Product - Blower Intended Use The blower is designed for forced air circulation in automotive and off-highway vehicle HVAC (Heating, Ventilation, and Air Conditioning) systems. It is suitable for applications where consistent airflow, long service life, and robustness in harsh environmental conditions are required Target Market The blower assembly is primarily intended for integration into HVAC systems across a wide range of vehicle segments. Its robust design, high airflow capacity, and long service life make it well-suited for automotive OEMs and Tier-1 suppliers involved in producing climate control systems for passenger and commercial vehicles. It is also a preferred choice for bus and coach manufacturers requiring reliable air circulation in large passenger compartments. Beyond on-road applications, the blower serves the needs of off- road and agricultural equipment manufacturers, where equipment operates in harsh environmental conditions and demands consistent ventilation performance. Additionally, spe....

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....Notes 2 to 5 of Section XVI of the Customs Tariff Act, 1975, which are as below: Subject to Note 1 to this Section, Note 1 to Chapter 84 and to Note 1 to Chapter 85, parts of machines (not being parts of the articles of heading 8484, 8544, 8545, 8546 or 8547) are to be classified according to the following rules: (a) parts which are goods included in any of the headings of Chapter 84 or 85 (other than headings 8409, 8431, 8448, 8466, 8473, 8487, 8503, 8522, 8529, 8538 and 8548) are in all cases to be classified in their respective headings; (b) other parts, if suitable for use solely or principally with a particular kind of machine, or with a number of machines of the same heading (including a machine of heading 8479 or 8543) are to be classified with the machines of that kind or in heading 8409, 8431, 8448, 8466, 8473, 8503, 8522, 8529 or 8538 as appropriate. However, parts which are equally suitable for use principally with the goods of headings 8517 and 8525 to 8528 are to be classified in heading 8517, and parts which are suitable for use solely or principally with the goods of heading 8524 are to be classified in heading 8529; (c) all other parts ....

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....entry by virtue of the purpose for which it is put to, the end use to which the product is put to, cannot determine the classification of that product. 3.6. Absence of Temperature Control Functionality It is important to emphasize that the Applicant's condenser fan does not regulate or control temperature. The fan's sole purpose is to move air to aid heat exchange in an external system (the bus AC condenser or radiator). Therefore, it does not fall under HSN headings that cover air-conditioning machines, refrigeration equipment, or temperature-regulating devices. Instead, it aligns more closely with HSN codes that cover independent fans or blowers without additional integrated functions. 3.7. Functional and Technical Basis for HSN 8414 Classification 1. Design and Construction: The product consists of a motor, fan blades, mounting frame, and electrical connectors - all characteristic features of industrial axial fans. 2. Operational Function: It produces directed airflow to assist heat transfer, without modifying the air's thermal properties by itself. 3. Market Identification: In trade and technical literature, it is sold and recogni....

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....de and does not have any temperature control. The same involves fans and these fans blow the air out and creates a vacuum in the area and this vacuum is filled by the fresh air. Hence, this allows circulation of air and, hence, is an Air Circulator which is covered under HSN 8414 59 30 which deals with Industrial Fans and blowers. 3. Advance Ruling is being sought in respect of the classification of the said product under the Customs Tariff/HSN between 8414 and 8415 and the applicable GST rate under the CGST Act, 2017. Comments on the application of applicant are as under: - Para 1 No comments are required. 1.1 to 1.2 No comments are required. 1.3 Comments are as par para 4.8 below 2 to 2.3 No comments are required. 2.4 A condenser fan/ blower being specialized AC parts, are distinctly used under chapter head 8415. It is typically a component used in AC system, refrigeration units or heat pumps to circulate air over the condenser coils for heat dissipation. 2.5 to 2.6 No comments are required. 3 to 3.5 No comments are required. 4 to 4.7 No comments are required. 4.8 The chapter heading 8415 is also covered apparatus which,....

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....submission already made by them. F. DISCUSSIONS AND FINDINGS 1. We have carefully examined the statement of facts, the application filed by the applicant, the submissions made during the personal hearing, and the comments from the jurisdictional Tax Authority. We also considered the issues involved for which the advance ruling is sought, along with other relevant facts and documents placed on record. 2. The issue raised by M/s. PEE AAR AUTOMOTIVE TECHNOLOGIES PRIVATE LIMITED, E-311, E-312, General Zone, Industrial Area Ghiloth, Shahjahanpur, ALWAR-301706, Rajasthan is fit to pronounce an advance ruling as it falls under the ambit of Section 97(2)(a) of the CGST Act, 2017 given as under :- "Classification of any goods or services or both" 3. We have noted that the product described as a "Condenser Fan" is designed for use in heavy-duty bus rooftop and engine applications. It consists of an electric motor that drives aerodynamic blades housed in a protective shroud, creating high-volume axial airflow. Its primary function is to force hot air away from the condenser coil or radiator. The applicant has claimed that this product is marketed and recognised in trad....

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....t-system" 8415 10 10 --- Window or wall types, self-contained or split-system 8415 10 90 --- Other 8415 20 - Of a kind used for persons in motor vehicles 8415 20 10 ---  For buses 8415 20 90 --- Other 8415 81 -- Incorporating a refrigerating unit and a valve for reversal of the cooling or heat cycle ("reversible heat pumps") 8415 81 10 --- Sub-types 8415 81 90 --- Other 8415 82 --  Incorporating a refrigerating unit but without a valve for reversal of the cooling-heat cycle 8415 82 10 --- Split air-conditioners 8415 82 90 --- Other 8415 83 -- Not incorporating a refrigerating unit but incorporating elements for changing temperature and humidity 8415 83 10 --- Split air-conditioners 8415 83 90 --- Other 8415 90 - Parts 6. Note 2 (b) to Section XVI provides that parts which are goods included in any heading of Chapter 84 or 85 are classified in that heading; other parts suitable for use solely or principally with a particular kind of machine are to be classified with that machine. 7. The "Condenser Fan" and "Blower" manufactured and su....