Composite mobile phone module classified as a phone part, securing concessional customs duty benefit under the notification.

A composite Cover Glass Module with display flex, sensor flex, ambient light sensor, magnetic compass and driver IC was treated as a part of a cellular mobile phone, not as a standalone display module. Applying the General Rules of Interpretation, HSN guidance, Chapter Note 7 to Chapter 85 and Section Note 2(b) to Section XVI, the AAR found that its multiple functions and sole design for mobile phones supported classification under CTH 8517 79 90. Because that tariff classification and the end-use condition were satisfied, the module was also eligible for concessional BCD under Sr. No. 6J of Notification No. 57/2017-Customs for manufacture of cellular mobile phones.

---

---

Issues: (i) Whether the Cover Glass Module exported by the applicant was classifiable under CTH 8517 79 90 of the Customs Tariff. (ii) Whether the Cover Glass Module was eligible for concessional BCD under Sr. No. 6J of Notification No. 57/2017-Customs for use in manufacture of cellular mobile phones.

Issue (i): Whether the Cover Glass Module exported by the applicant was classifiable under CTH 8517 79 90 of the Customs Tariff.

Analysis: The product comprised a top module, display flex, sensor flex containing ambient light sensor and magnetic compass, and driver IC, and was integrated into the mobile phone after import. Applying the General Rules of Interpretation, the HSN guidance, Chapter Note 7 to Chapter 85 and Section Note 2(b) to Section XVI, the decisive question was whether the product remained a mere flat panel display module or had assumed the character of goods of another heading. Because the module performed multiple functions beyond display, and was specially designed for use solely with mobile phones, it was treated as a part of mobile phone rather than as a standalone display module under heading 8524.

Conclusion: The Cover Glass Module was held classifiable under CTH 8517 79 90, in favour of the assessee.

Issue (ii): Whether the Cover Glass Module was eligible for concessional BCD under Sr. No. 6J of Notification No. 57/2017-Customs for use in manufacture of cellular mobile phones.

Analysis: Sr. No. 6J grants concessional BCD to goods falling under CTH 8517 79 90 when used in the manufacture of cellular mobile phones, subject to compliance with the concessional-import procedure. Since the Cover Glass Module was found to be classifiable under CTH 8517 79 90 and to be used in mobile phone manufacture, the notification benefit followed.

Conclusion: The Cover Glass Module was held eligible for the concessional BCD benefit under Sr. No. 6J, in favour of the assessee.

Final Conclusion: The ruling affirms both the classification of the product as a mobile phone part and its entitlement to the related concessional customs duty benefit.

Ratio Decidendi: Where a composite imported module has multiple independent functions and is specially designed for sole use with a cellular mobile phone, it is classifiable as a part of that phone under Section Note 2(b), and the corresponding concessional notification benefit applies if the tariff and end-use conditions are met.

---