Composite import classification of BTS equipment: antenna and installation materials cannot be split from the integrated package for higher duty

A composite import of a Base Transreceiver Station, antenna and installation materials was treated as one integrated package for tariff purposes, because the invoice showed a single value and the technical material indicated that the BTS itself includes radio transmission and reception devices, including antennas. The exemption entry for BTS under Notification No. 21/2002 was held to cover the imported assembly, so the antenna and installation items could not be segregated and assessed under a separate higher-duty entry when they formed part of the BTS package as imported. Separate tariff treatment was limited to antennae imported as independent goods, and the revenue challenge failed.

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Issues: Whether antenna and installation cable imported along with Base Transreceiver Station could be segregated from the BTS for the purpose of denying the benefit of Notification No. 21/2002 and charging higher duty under a separate entry.

Analysis: The imported consignment consisted of BTS together with antenna and installation materials, and the invoice reflected the entire value without separate valuation of the auxiliary items. The notification entry for BTS covered the cellular mobile telephone service equipment specified in List 22, which included BTS and allied radio communication equipment. Technical material relied upon in the decision showed that the BTS itself contains radio transmission and reception devices, including antennas, and therefore the antenna is not a detachable external item when imported as part of the BTS assembly. Separate tariff treatment of antenna under a different entry was held to apply only when antennae are imported as independent goods and not when they form part of the BTS package as imported.

Conclusion: Antenna and installation materials were held to be integral and inseparable parts of the BTS, and the revenue appeal failed.

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