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SGST AAAR

GST – Punjab AAAR - Classification of roof mounted Air conditioning unit especially for use in railway coaches - whether roof mounted Air conditioning unit especially for use in railway coaches and manufactured as per railway design is classifiable under HSN 8415 1090 or under HSN 8607 99 as parts of Railway Coaches/ Locomotives – Appellant aggrieved by Advance Ruling order holding that the Roof Mounted Air-Conditioning unit manufactured by the applicant are classifiable under HSN Heading 8415 and the classification of the subject goods shall not alter on account of supply to Railways – HELD – The Heading 8415 is wide enough to cover within its realm all kind of air conditioning machines irrespective of the fact that whether the same are manufactured in such a manner to be installed on a particular vehicle or a machine or even a location. It can be inferred that once the said good is classified under the heading 8415, then by virtue of the clause (e) of the Section Note 2 of the Section XVII, the same is excluded from classification under heading 8607 – The above line of argument is further amplified by Explanatory notes to the Chapter 84 which clearly brings out the fact that the industry in which the said goods are deployed is immaterial for determining the classification and the same should be guided by the function which it is expected to perform - the good under contention i.e. ‘Roof Mounted Air Conditioning Units’ being manufactured by the appellant have a specific function to perform, that is of air conditioning and same should clearly be covered under the heading 8415 and not under 8607 - Order issued by the Authority for Advance Ruling is upheld and the appeal is rejected
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