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2009 (5) TMI 159 - AT - Central ExciseBulk Milk Cooling Tank – classification - Bulk Milk Cooling Tank consists of milk vessel, ice water vessel, heat exchangers coil and condensing unit. The cooling coil immersed in water vessel produces ice. The ice water is sprayed on the outside surface of the milk vessel thereby maintaining the temperature at 4 degree Centigrade. Thus in effect though the milk may be maintained at around 4 degree Centigrade, the machinery do have the refrigerating function of generating ice. As per the explanatory note to CH. 8418, the temperature at the active cooling element is what is important and not the temperature of the refrigerated product. – Impugned tank is classifiable under SH 8418.10 and not under SH 8419.10 – The explanatory notes to the HSN are a safe guide and aid for ascertaining the true meaning of any expression used in the Act in case of any doubt and that the explanatory notes to HSN are not only of persuasive value but are entitled to greater consideration in classifying goods
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