Customs classification of EPS-ECU upheld as motor vehicle steering part, not Chapter 90 apparatus, on identical goods reasoning.

Imported Electronic Power Steering- Electronic Control Unit (EPS-ECU) was held to be classifiable as a part of the motor vehicle power steering system under CTI 8708 94 00, not as an apparatus of Chapter 90 under CTI 9032 90 00. The Tribunal applied its earlier final order in the appellant's own case, noting that the present goods were identical to those already considered and that later decisions on different ECUs did not displace that position because classification depends on the specific goods. The earlier classification ruling therefore continued to govern, and the Revenue's view was upheld.

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Issues: (i) Whether the imported Electronic Power Steering- Electronic Control Unit (EPS-ECU) was classifiable under Customs Tariff Item 8708 94 00 as a part of motor vehicle power steering system or under Customs Tariff Item 9032 90 00 as claimed by the appellant.

Analysis: The dispute was identical to the earlier appeals decided in the appellant's own case. The Tribunal noted that the earlier final order had already held EPS-ECU to be a part of the power steering system and not an instrument or apparatus falling under Chapter 90. It further noted that subsequent Chennai Bench decisions on different ECUs did not alter the position because classification depends on the specific goods and the present ECU was identical to the one previously considered. In these circumstances, the earlier decision continued to govern the issue.

Conclusion: EPS-ECU was correctly classifiable under CTI 8708 94 00 and not under CTI 9032 90 00. The finding was against the appellant and in favour of the Revenue.

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