2004 (8) TMI 135

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....rted by stainless steel frames with hinges and latches. (c) Polyurethane foam panels consists of 61% foam and 8.39% painted steel while doors have 59% foam and 41% painted steel. The panels form the wall section, door and roof and floor sections are also made in standard sizes to result in composite construction of polyurethane foam in place, between two metal sheets enclosing a space. They can be assembled to erect a pre-fabricated room, of different sizes as per requirement for cold or hot storage. (d) Architect certificates have been produced to claim the entities as use of the same in buildings distinct from Refrigerating equipment and they are not panels and doors sold as Cabinets for Refrigerating equipments. (e) (i) Trade Notice o....

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....rs relying upon explanatory notes under 8418 holding that Cold room size being large or small would not disqualify them from being 'cabinets'. (h) That the panels, doors herein are parts of a large sized room where desired temperature and insulation from external temperature are to be maintained without doubt is the use and purpose. They are in full or parts of such a Huge Cold Storage Rooms. They are fabricated/erected at site and refrigeration units supplied, then they became walk in Cold Storages. They are evidently not 'Cabinets' as understood for equipments like a freezer, domestic or commercial or a Refrigerator. Classification of such Cold Storage Rooms, warehouse Plants at Site have been held to be not of an excisable goods by the ....