Classification of metal core printed circuit boards as printed circuits under Tariff Item 8534, appeal allowed and order set aside

Whether metal core printed circuit boards fall under Tariff Item 8534 or as parts of luminaires under Tariff Item 9405 turned on statutory classification using the Customs Act framework, the Customs Tariff Act, the General Rules for Interpretation and Chapter/Section notes. Chapter Note 8 treats printed circuits by description irrespective of cladding, and parts falling within Chapter 85 must be classified there. An IGST rate notification is inapposite to tariff classification. Prior tribunal precedents supported classification under 8534 and the revenue failed to discharge its burden; result: goods classifiable under 8534 and impugned order set aside.

---

---

Issues: (i) Whether metal core printed circuit boards (MCPCBs) imported are classifiable under Tariff Item 8534 00 00 as "printed circuits" or under Tariff Item 9405 99 00 as parts of luminaires.

Analysis: The classification must follow Section 12 of the Customs Act, 1962 and Section 2 and the First Schedule to the Customs Tariff Act, 1975, applying the General Rules for Interpretation (GIR) and relevant Chapter and Section Notes. Chapter Note 8 to Chapter 85 defines "printed circuits" and indicates coverage irrespective of constituent cladding where the product falls within the statutory description. Section/Chapter notes and Note 2 to Section XVI guide classification of parts and direct that goods falling within a specific heading of Chapter 85 be classified therein. The assessing authority relied on an entry in an IGST rate notification, which relates only to tax rates and does not alter statutory classification under the Customs Tariff Act. The Tribunal has previously decided identical issues in favour of classification under 8534 00 00 (citing Crompton Greaves and subsequent coordinate decisions), and higher court disposals confirmed non-interference with those Tribunal findings; the revenue did not discharge the onus of proof to show exclusion from the specific 8534 description.

Conclusion: The MCPCBs are classifiable under Tariff Item 8534 00 00 as printed circuits; the impugned order classifying the goods under Tariff Item 9405 99 00 is set aside and the appeals are allowed in favour of the appellants (assessee).

---