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Issues: Classification of industrial cold storage doors under Customs Tariff and applicability of Notification 172/89.
In this judgment by the Appellate Tribunal CEGAT, Mumbai, the issue at hand was the classification of industrial cold storage doors under the Customs Tariff and the applicability of Notification 172/89. The appellant had imported these doors and claimed their classification under Heading 8418.99 as parts of refrigeration machinery, seeking the benefit of the aforementioned notification. However, the Custom House contended that the doors should be classified under 7308.30 as structures of iron and steel. The Assistant Collector, whose decision was upheld by the Collector (Appeals), ruled in favor of the Custom House, denying the benefit of the notification. The appellant then appealed this decision. The appellant argued that the cold storage doors were specially fabricated for use in cold rooms, also known as walk-in coolers, and were intended for storage requiring refrigeration. They referenced manufacturer pamphlets describing the doors as Enviro cold storage doors, emphasizing their specialized features for refrigeration purposes. On the other hand, the Departmental Representative contended that the doors were not distinct from regular doors used in metal structures, asserting that the addition of insulation and specific design elements did not change their fundamental function as doors of iron and steel. They argued that the doors were not parts of machinery but rather components of large rooms, classifiable under Heading 73.02 as parts of base metal structures. The Tribunal examined the pamphlet provided by the appellant, detailing the features of the Enviro doors, such as steel-reinforced panels, insulation with high insulating qualities, and specialized components for different applications like meat processing. The Tribunal concluded that these doors were more than ordinary doors and had features specifically tailored for use in freezers, indicating a classification under Heading 8418.99 for refrigerating furniture. Additionally, the Tribunal referred to the explanatory note of the Harmonised System of Nomenclature, which clarified that items like cabinets and refrigerating furniture designed to receive refrigeration units fell under Heading 84.18. Considering the specialized features and intended use of the doors, the Tribunal upheld the appellant's classification argument under Heading 8418.99. Moreover, the Tribunal dismissed the notion that the doors' installation in large cold rooms disqualified them from being considered as cabinets, citing references from refrigeration literature regarding walk-in coolers of varying sizes. The Tribunal emphasized that the doors met the criteria for classification under Heading 8418.99 as refrigeration cabinets. In conclusion, the Tribunal allowed the appeal, setting aside the previous order and providing for any necessary consequential relief.
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