Summarize the following court judgment. ivil Appeal No. 3395 of 1982. From the Judgment and Order dated 4.6.1982 of the Punjab and 572 Haryana High Court in L.P.A. No. 936 of 1982 Shankar Das and H.K. Puri for the Appellant. A.K. Ganguli	 R.P. Srivastava	 P. Parameshwaran	 Ms. A. Subhashini and Dalip Sinha for the Respondents. The Judgment of the Court was delivered by V. RAMASWAMI	 J. The appellants are a public limited company having a factory at Faridabad and engaged in manu facturing air conditioning and refrigeration equipment of various kinds and descriptions. They are holding a L 4 Licence to manufacture goods falling under Tariff Item No. 29A of the Central Excise Tariff. As per classification lists submitted from time to time under rule 173B of the Central Excise Rules	 1944	 the company had declared in Form I that they are engaged in the manufacture of goods falling under sub items (2) and (3) of Tariff Item No. 29A. Against gate pass Nos. 111	 112 and 113 dated January 21	 1970 and gate pass No. 116 dated January 22	 1970 the appellants had cleared from the factory cooling coils	 condensors and compressors and supplied the same for putting up a cold storage plant to one M/s Ravi Cold Storage	 Ahmedabad. These parts were manufactured by the appellants in their factory at Faridabad and were cleared by them against the above mentioned gate passes after payment of a duty of Rs. 13.547.20 P. Against gate pass Nos. 95	 90	 97 and 98 dated January 21	 1969 the appellants had cleared from the factory various parts of refrigerating and air conditioning appli ances and machinery for an Ice factory plant to one M/s Gujarat Industrial Investment Corporation Limited	 Ahmeda bad. These parts also were manufactured by the appellants in their factory at Faridabad and were cleared by them against gate passes referred to above after payment of a duty of Rs. 19	336.87 P. On the ground that parts of the refrigerating and air conditioning appliances which they have removed under the above said gate passes are not excisable goods falling under Tariff Item No. 29A(3)	 they filed two refund applications. The Assistant Collector of Customs rejected both these applications holding that the assessment was made correctly. The appellants preferred two appeals agianst these orders before the Collector of Customs and Central Excise	 Chandi garh	 who by his common order dated December 20	 1971 dis missed the appeals. Thereafter	 the appellants filed writ petition in the High Court of Punjab and Haryana at Chandi garh. This writ petition was 573 dismissed by a learned Single Judge holding that the goods supplied are parts of a refrigerating and air conditioning appliances	 that a complete cold storage plant was not supplied to M/s Ravi Cold Storage	 Ahmedabad or M/s Gujarat Industrial Investment Corporation Ltd. Ahmedabad	 and that they will fall clearly within the purview of Tariff sub item (3) of Tariff Item 29 A. An appeal preferred against this judgment was dismissed in limine by a Division Bench. In order to understand the argument of the learned counsel for the appellants	 it is necessary to set out Tariff Item 29 A in full at the relevant period	 which reads as follows: Item No. Tariff Description Rate of Duty 29A. REFRIGERATING AND AIR CONDITIONING APPLIANCES AND MACHINERY	 ALL SORTS	 AND PARTS THEREOF (1) Refrigerators and other refrigerat Thirty ing appliances	 which are ordinarily per cent sold or offered for sale as ready ad valorem assembled units	 such as ice markers	 bottle collers	 display cabinets and water coolers. (2) Air conditioners and other air Thirty conditioning appliances	 which per cent are ordinarily sold or offered ad valorem for sale as ready assembled units	 including package type of air conditioners and evaporative type of coolers. (3) Parts of refrigerating and Forty air conditioning appliances per cent and machinery	 all sorts. ad valorem The argument of the learned counsel for the appellants was that sub items (1) and (2) deal with refrigerators and other refrigerating appliances and air conditioners and other air conditioning appliances respectively which are ordinarily sold or offered for sale as a ready 4514 assembled unit. Therefore	 in order to bring it within sub items (1) and (2) such refrigerating and air conditioning appliances should be complete assembled units and they must also be ordinarily sold or offered for sale as such ready assembled units. The illustrative examples referred to in the two sub items make this clear according to them. The cold storage plant and ice factory plant supplied to the factories concerned in this case as such are not such com plete assembled units which are ordinarily sold or offered for sale within the meaning of sub items (1) and (2). From this premise they sought to interpret sub item (3) as mean ing that the goods that are covered by that sub item are parts of those refrigerating or air conditioning appliances which in its assembled form would have come as a complete unit under Tariff sub items (1) and (2) of Item 29A and are manufactured for sale. In other words	 they want to restrict the content of sub item (3) with reference to the items that may fall under sub items (1) and (2). The further submission was that though in its sweep sub item (3) may appear to cover all and every part of refrigerating and air condition ing appliances and machinery of all sorts	 the words "and parts therefore" in the heading controlled the meaning and restrict it in the context only to parts of a completed unit which as such completed unit would have come under sub items (1) and (2) of Item 29A. In this connection	 learned counsel has referred to certain decisions of the High Courts which we will refer to later. By Finance Act of 1961 Item 29A and 40 were introduced in the First Schedule to the and those two entries read as follows: "29A. AIR CONDITIONING MACHI Twenty NERY	 ALL SORTS. per cent ad valorem. REFRIGERATORS AND PARTS Twenty THEREOF. SUCH AS ARE per cent SPECIALLY DESIGNED FOR USE ad valorem." WITH REFRIGERATORS. The Notes on Clauses relating to the relevant clause in the Finance Bill 10 of 1961 stated that Item 29A proposes to levy an excise duty on air conditioning machinery and Item 40 proposes to levy an excise duty on refrigerators and "parts thereof. " By the Finance Act 2 of 1962 a combined tariff entry in the form 575 prevailing in 1969 and 1970 was introduced and the Notes on Clauses relating to this amendment stated that the proposal is "to combine into one item the present tariff items 29A and 40 relating to 'Air conditioning Machinery ' and 'Refrig erators ' respectively as well as to make it more comprehen sive. " Under the Government of India	 Ministry of Finance	 Department of Revenue	 Notification No. 80/62 Central Ex cises	 dated 24th April	 1962 as subsequently amended by Notifications dated 29th December	 1962	 23rd March	 1968 and 14th June	 1969 all parts of refrigerating and air conditioning appliances and machinery other than the "parts" mentioned below were exempt from the payment of excise duty leviable thereon: "(i) Cooling coils or evaporator (ii) Compressor (iii) Condenser (iv) Thermostat (v) Cooling unit	 and in the case of absorption types of refrigerators in which there is no compressor	 heater including Burners and Baffles in a Kerosene Operated absorp tion type refrigerator. (vi) Starting Relay	 controls (including expansion value and solenoid valves) and pressure switches (vii) Overload Protection/Thermal Relay (viii) Cabinet. " There are a number of other notifications also exempting parts of refrigerating and air conditioning appliances and machinery	 intended to be used for various purposes speci fied in the notifications	 such as	 use in refrigerating and air conditioning appliances or machinery which are installed or to be installed in any of the following establishments: "1. Computer rooms. Research and test laboratories 3. Animal houses 4. Telephone exchanges 5. Broadcasting studios 6. Trawlers 7. Dams 8. Mines and tunnels 9. Thermal and hydel power stations 10. 576 Technical buildings of Military Engineering Service 11. Any Hospital run by the Central Government	 a State Govt.	 a Local Authority or a Public Charitable Institution and 12. Any factory. " Vide the Notification No. 93/76 CE dated 16.3.1976 issued under subitem (3) of Item 29A of the First Schedule. there are various other notifications also issued under the same sub item which covers installation of air condition and refrigerating equipments of almost all categories. The legislative history and the notifications of the Government show that sub item (3) of Item 20A is a compre hensive provision encompassing within it parts of all sons of air conditioning and refrigerating appliances and machin ery and the Government of India was issuing notifications of exemptions on the understanding that such parts are covered by sub item (3). The language used in sub item (3) is also wide and comprehensive in its application and could not be given a restricted meaning. Sub items (1)	 (2) and (3) are independent of each other and mutually exclusive. The scope of sub item (3) is neither restricted nor controlled by the provisions of sub items (1) and (2). It is well settled that the headings prefixed to sec tions or entries cannot control the plain words of the provision; they cannot also be referred to for the purpose of construing the provision when the words used in the provision are clear and unambiguous; nor can they be used for cutting down the plain meaning of the words in the provision. Only	 in the case of ambiguity or doubt the heading or sub heading may be referred to as an aid in construing the provision but even in such a case it could not be used for cutting down the wide application of the clear words used in the provision. Sub item (3) so construed is wide in its application and all parts of refrigerating and air conditioning appliances and machines whether they are covered or not covered under sub items (1) and (2) would be clearly covered under that sub item. Therefore	 whether the manufacturer supplied the refrigerating or air condi tioning appliances as a complete unit or not is not relevant for the levy of duty on the parts specified in sub item (3) of Item 29A. Strong reliance was placed by the learned counsel for appellants on the decision of the Allahabad High Court in Mother India Refrigeration Industries (P) Ltd. vs Superin tendent of Central Excise & Ors.	 All. In that case the writ petitioners were the owners 577 Of a old storage plant. The writ petitioners themselves installed and assembled the cold storage plant. Part of the plant consisted of erecting locally what are called cooling coils and condensers. Generally cooling coils and condensers contain a very long length of pipes made in a particular shape. The petitioners in that case	 however	 bought pipes of various lengths	 erected them one after the other and joined one with the other with a 'U ' shape bend. These bends were welded. The result was that the various pipes consti tuted an unit indesigning the plant. This part of the plant was necessary in order to pass the cooling gas through it and thereby cool the chambers of the storage. The petition ers bought the pipes and the bends from the market and got them placed at the factory site and got them welded. The department	 in the view that the conglomeration of pipes manufactured by the petitioner	 constituted manufacture of cooling coils which are parts of refrigerating and air conditioning appliances and machinery covered by Item 29A(3) called upon the petitioners to pay excise duty on its value. All the authorities found that the erection and installation by the petitioners	 by laying pipes and joining them by welded bends	 amounted to the manufacture of cooling coils and condensers as known to refrigeration technology. The High Court accepted these findings. However	 it held that parts of refrigerating and air conditioning appliances which answer the description given in sub items (1) and (2) alone are liable to duty under Entry 29A(3) and not all parts used in refrigeration technology. The learned judges reached this conclusion on the grounds that: "The heading of Entry 29A makes it clear that only parts of such refrigerating and air conditioning appliances and machinery as are covered by sub entries (1) and (2) alone are liable to duty. In other words	 the parts in question should be such as are ordinarily sold or offered for sale as ready. assembled units. On any other interpretation the words 'thereof ' occurring in the heading 29A will be redun dant. An interpretation which makes any part of a statute redundant has to be discarded." and that "When an entry in the schedule specifically refers to and re stricts the applicability of duty to goods which are assembled units and which are generally offered for sale	 the concept of sale is necessarily brought in. As already seen	 sub entry (3) takes it colour from sub entries (1) and (2) because of the specific directive of the heading by using the words 'parts thereof '. " 578 We are afraid that both these reasons are fallacious and not acceptable. As already stated neither can sub entry (3) be said to take its colour from sub entries (1) and (2) nor could those sub entries or heading curtail the plain meaning of the words used in sub entry (3). We	 therefore	 hold that the Mother India Refrigeration Industries (P) Ltd. vs Supdt. of Central Excise & Ors. 's	 case (supra)	 was wrongly decided and accordingly we overrule the same. The learned Judges have also relied on a Tariff Advice dated September 30	 1969 given under the Customs Act for the purpose of levying countervailing duty. We shall deal with this ques tion when we consider that Tariff Advice in a latter part of this judgment. The decisions of the Bombay High Court in Blue Star Ltd. vs Union of India & Anr.	 Bom. and Joy Ice Cream	 Bombay vs Union of India	 Bom.	 related to the scope of Tariff item 29A(1) and not Item 29A(3) with which we are concerned. In the view we have taken that sub entries (1) and (2) of Entry 29A cannot control or restrict the meaning of such entry (3) it is not necessary for us to go into the scope of Entry 29A (1) and (2). These decisions	 therefore	 are no relevance. The decision of the Kerala High Court in Calicut Refrig eration Co. vs Collector of Customs & Central Excise	 Cochin & Ors.	 Ker.	 also does not touch upon the question with which we are concerned. The decision of the Allahabad High Court in Chhibramau Cold Storage vs CEGAT	 All. and Goptal Cold Storage & Ice Factory vs Union of India & Ors.	 All.	 simply followed the decision in Mother India Refrigeration Industries (P) Ltd. vs Supdt. of Central Excise & Ors.	 (supra) and	 there fore	 they do not advance the case any further. On the other hand	 we have a decision of the Gujarat Court in Anil Ice Factory & Anr. vs Union of India & Ors.	 Guj.	 wherein M.P. Thakkar	 Chief Justice	 as he then was	 referred to the Allahabad High Court judgment and dissenting from it held: "On taking a close look at Item 29A it will be seen that what is printed at the top of the entry as "caption" indi cates the nature of the goods covered by the entry. It does not more than indicate what is the nature of the goods which are specified in the said entry. (1)	 (2) and (3) are independent of each other. Clause (3) in terms refers to goods which fall within the description of the said entry	 579 namely	 "Parts of refrigerating and air conditioning appli ances and machinery	 all sorts". It is not disputed that cooling coils and condensers would fall within the category of "appliances and machinery". Counsel however argues that we must first read the scope of cl. (1) and cl. (2) and draw an inference therefrom that the goods covered by entry	 will attract excise duty only provided they are manufactured for sale. We see no valid reason for reading the entry in that manner. Each of the three sub clauses referes to different entries and specifies different rates of duty for the goods falling within the respective entries." and that "As we indicated earlier	 in the first place the purpose of the caption is to provide a clue to the nature of the goods which are covered by the entry. But even otherwise if the caption is read in the manner in which it has been worded it does not justify or warrant an inference that it related to goods which are manufactured for the purpose of sale. Entry 29A adverts to goods which would fall within one or the other of the three classifications specified therein. The description of each category of goods if clearly mentioned in col. So far as CI. (3) is concerned the tariff description is "parts of refrigerating and air conditioning appliances and machinery". We cannot read the words 'manufactured for sale ' in entry No. 3 by drawing upon the theory of "Taking colour" which has no application in a case like the present one. If we inject these words we would be re writing this section and we would be legislating which we cannot do. " The learned counsel for the appellants then relied on the Trade Advice dated 30th September	 1969 given by the Central Board of Excise and Customs	 New Delhi	 in respect of classification of refrigerating machinery and ice making plant which are not sold or offered for sale as ready assem bled unit for purposes of countervailing duty under the Customs Act. After referring to sub items (1) and (2) of Item 29A as covering complete plant and equipment which a re ordinarily sold or offered for sale as ready assembled units	 had stated as follows	 with reference to sub item (3): "Sub item (3) of item 29A of the Central Excise Tariff 580 refers to parts or ' machinery and appliances and complete plants which cannot be considered as "parts of machinery" would not be classifiable under sub item (3) to item 29A C.E.T. also. " As may be seen from this paragraph it consists of two parts	 the first portion referring to parts of machinery and appli ances and the second portion referring to complete plants which cannot be considered as parts of machinery. The whole argument arose because of the composite sentence used in this paragraph. It only means complete plants which are covered by Items (1) and (2) cannot be considered as parts on machinery and such complete plants would not be classi fiable under sub item (3) of Item 29A. The reliance placed by the learned counsel on this notification does not in any way advance the case of the appellants. In the foregoing circumstances	 the appeal fails and it is dismissed with costs. Y. Lal Appeal dismissed.

The appellant company was engaged in the manufacturing of airconditioning and refrigeration equipment under a proper licence. On January 21	 1970 the appellant cleared from the factory cooling coils	 condensers and compressors and supplied the same to M/s. Ravi Cold Storage	 Ahmedabad for putting up a cold storage and paid duty of Rs.13	547.20 P in respect thereof. Again on January 21	 1969	 the appel lant cleared from the factory various parts of refrigerating and air conditioning appliances and machinery for an Ice factory plant to one M/s. Gujarat Industrial Investment Corporation Ltd.	 Ahmedabad and paid a duty of Rs. 19	336.87P. Both the aforesaid goods were manufactured at the appellant 's factory. Thereafter the appellant filed two refund applications of the said excise duty before the Assistant Collector of Customs	 contending that the refrig erating and air conditioning appliances which they had removed on the aforesaid dates were not excisable goods failing under Tariff Item No. 29A(3). The Assistant Collec tor of Customs rejected both the applications holding that the assessment was correctly made. The appellant company preferred two appeals against these orders before the Col lector of Customs and Central Excise	 Chandigarh	 who dis missed both the appeals. Thereupon the appellant filed a writ petition in the High Court. The learned single Judge who heard the petition dismissed the same holding that the goods supplied are parts of a refrigerating and air condi tioning appliances	 that a complete cold storage plant was not supplied to M/s. Ravi Cold Storage	 Ahmedabad or M/s. Gujarat Industrial Investment Corporation Ltd.	 Ahmedabad and that they would fail clearly within the purview of Tariff sub item (3) of Tariff Item 29 A. An appeal preferred against this judgment was dismissed by a Division Bench in limine. Hence this appeal. Before this Court also the appellant inter alia contended that 571 though in its sweep sub item (3) may appear to cover all and every part of refrigerating and air conditioning appliances and machinery of all sorts	 the words "and parts thereof" in the heading controlled the meaning and restrict it in the context only to parts of a completed unit which as such completed unit would have come under sub items (1) and (2) of item 29 A. Dismissing the appeal	 this Court	 HELD: The legislative history and the notifications of the Government show that sub item (3) of item 29 A is a comprehensive provision encompassing within it all sorts of air conditioning and refrigerating appliances and machinery and the Government of India was issuing notifications of exemptions on the understanding that such parts are covered by sub item (3). The language used in sub item (3) is also wide and comprehensive in its application and could not be given a restricted meaning. Sub items (1)	 (2) and (3) are independent of each other and mutually exclusive. The scope of sub item (3) is neither restricted nor controlled by the provisions of sub items (1) and (2). [576C D] Whether the manufacturer supplies the refrigerating or airconditioning appliances as a complete unit or not is not relevant for the levy of duty on the parts specified in sub item (3) of item 29 A. [576F G] Complete plants which are covered by items (1) and (2) cannot be considered as parts of machinery and such complete plants would not be classifiable under sub item (3) of Item 29 A. [580B C] Mother India Refrigeration Industries Pvt. Ltd. vs Supdt. of Central Excise and Ors.	 All	 overruled. Blue Star Ltd. vs Union of India and Anr.	 Bom. ; Joy Ice Cream	 Bombay vs Union of India	 Bom.; Calicut Refrigeration Co. vs Collector of Customs & Central Excise	 Cochin and Ors. 	 Ker.; Chhibramau Cold Storage vs CEGAT	 ; Goptal Cold Storage & Ice Factory vs Union of India and Ors.	 and Anil Ice Factory & Anr. vs Union of India and Ors.	 	 referred to.