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The narration of Rule of GIR supra clearly elaborates that when 2 or more headings seem to apply for a product, the one which provides the most specific description of the product should be used. In the instant case, it appears that the air conditioners which have both cooling and heating capacity is appropriately sub-heading 841581 rather than in the sub-heading 841510. In support of my contention that the heading which provides the most specific description shall be preferred to the Heading providing a more generic description, I rely upon the following decisions

30 C/85759,86106,86107,86143,86144,86145,86146/2017, "THE FIRST SCHEDULE- IMPORT TARIFF GENERAL RULES FOR THE INTERPRETATION OF THIS SCHEDULE Classification of goods in this Schedule shall be governed by the following principles:
1. ********
2. ********
3. When by application of rule 2(b) or for any other reason, goods are, prima facie, classifiable under two or more headings, classification shall be effected as follows:
(a) The heading which provides the most specific description shall be preferred to headings providing a more general description. However, when two or more headings each refer to part only of the materials or substances contained in mixed or composite goods or to part only of the items in a set put up for retail sale, those headings are to be regarded as equally specific in relation to those goods, even if one of them gives a more complete or precise description of the goods.

In case of MOORCO (India) Ltd [1994 (74) ELT 5 (SC)], Hon'ble Supreme Court held as follows:

"The applicability of the rule arises when the goods consisting of more than one material fall in two or more headings. It is further clear that each of the classes are mutually exclusive. What is covered in (a) cannot be classified in (b) and (c) operates when neither applies. It is like a residuary clause. The primary 32 C/85759,86106,86107,86143,86144,86145,86146/2017, question, therefore, is whether the goods manufactured by the appellant fall in clause (a) as if it can be classified with reference to (a) then clauses (b) and (c) would not apply. Clause (a) incorporates the common and general principle that the goods which can be classified specifically with reference to any heading should be placed in that category alone. The specific heading of classification has to be preferred over general heading. The clause contemplates goods which may be satisfying more than one description. Or it may be satisfying specific and general description. In either situation the classification which is the most specific has to be preferred over the one which is not specific or is general in nature. In other words, between the two competing entries the one most nearer to the description should be preferred. Where the class of goods manufactured by an assessee falls say in more than one heading one of which may be specific, other more specific, third most specific and fourth general. The rule requires the authorities to classify the goods in the heading which satisfies most specific description. For instance, taking the case of the appellant the item manufactured by the appellant is described and used as flow meter. It is an instrument for measuring volume as well. Flow meter is specifically classified in Heading No. 90.24. Whereas the Heading 90.26 is general in nature. It applies to every production meter or calibrating meter for gas, liquid and electricity supply. Therefore, on the finding recorded by the Assistant Collector, the goods produced by the appellant specifically fall in Heading No. 90.24. They may also fall in Heading No.90.26 but that being more general entry preference should have been given to the entry 90.24 as the goods satisfy most specific description of being flow meter. The Tribunal or the appellate authority without adverting to it applied clause (c) and levied duty under 90.26 as it was a latter heading. But clause (c) would apply only if clauses
(a) and (b) do not apply. Since the goods manufactured by the appellant satisfied the specific description of Tariff Heading 90.24 being a flow meter, the Tribunal committed an error of law in classifying it under Tariff Heading 90.26 as it was a latter item under the classification list."

33 C/85759,86106,86107,86143,86144,86145,86146/2017, 4.10 Hence we are of the considered opinion that classification of RAC as determined by the Principal ADG cannot be sustained and the classification as claimed by the appellant under 84151010 is correct. Same view has been expressed by the tribunal in case of Daikin Air Conditioning [2020 (374) E.L.T. 768 (Tri. - Mumbai)] and International Aircon Private Limited [2020- TIOL-1536 MUM)]. In case of Daikin tribunal stated as follows: