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Issues: Whether Small Form Factor Pluggable (SFP) modules imported for telecommunication equipment are classifiable as parts of the telecom apparatus under Heading 8517 or as complete machines under sub-heading 8517 62, and whether they are eligible for exemption under Notification No. 24/2005-Cus.
Analysis: The imported SFP modules were found to operate only when fitted into the relevant telecom equipment and not as independent stand-alone apparatus. The reasoning accepted the manufacturer's clarification and the earlier appellate findings that the modules function as parts of the ethernet switch or other telecom equipment, supplying the interface between electrical and optical domains. On that basis, the goods were held to be parts of telecom equipment classifiable under Heading 8517, and the exemption available to goods of that heading was held applicable.
Conclusion: The SFP modules are classifiable as parts of telecom equipment under Heading 8517 and are entitled to the benefit of Notification No. 24/2005-Cus; the Revenue's challenge fails.
Ratio Decidendi: A module that does not perform its intended telecom function independently and operates only as an integral part of the host equipment is classifiable as a part of that equipment rather than as a complete machine.